Contingency Plan: Applications and Data Criticality Analysis-What to Do and How to Do It

In our series on the HIPAA Administrative Simplification Security Rule, this is the fifth implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is addressable.  Remember, addressable does not mean “optional.” Rather, an addressable implementation specification means that a covered entity must use reasonable and appropriate measures to meet the standard. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Assess the relative criticality of specific applications and data in support of other…

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Contingency Plan: Testing and Revision Procedures-What to Do and How to Do It

In our series on the HIPAA Administrative Simplification Security Rule, this is the fourth implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is addressable. Remember, addressable does not mean “optional.” Rather, an addressable implementation specification means that a covered entity must use reasonable and appropriate measures to meet the standard. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Implement procedures for periodic testing and revision of contingency plans. How to Do…

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Contingency Plan: Emergency Mode Operation Plan-What to Do and How to Do It

In our series on the HIPAA Administrative Simplification Security Rule, this is the third implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is required. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Establish (and implement as needed) procedures to enable continuation of critical business processes for protection of the security of electronic protected health information while operating in the emergency mode. How to Do It Covered entities are required to develop…

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Contingency Plan: Disaster Recovery Plan-What to Do and How to Do It

In our series on the HIPAA Administrative Simplification Security Rule, this is the second implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is required. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Establish (and implement as needed) procedures to restore any loss of data. How to Do It The content and procedures of a covered entity’s disaster recovery plan will be » Outcomes of the covered entity’s identification of vulnerabilities and…

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Contingency Plan: Sample Policy and Procedures

This is the seventh Administrative Safeguard Standard of the HIPAA Administrative Simplification Security Rule. It has five implementation specifications: Data backup plan; Disaster recovery plan; Emergency mode operation plan; Testing and revision procedures; and Applications and data criticality analysis. The first three are required; the last two are addressable. Addressable does not mean optional. Rather, an addressable implementation specification means that a covered entity must use reasonable and appropriate measures to meet the standard. Further, as HIPAA.com has noted earlier, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. HIPAA.com will outline What to do and How to do it for each…

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