Information Access Management: Isolating Healthcare Clearinghouse Functions-What to Do and How to Do It

In our series on the HIPAA Administrative Simplification Security Rule, this is the first implementation specification for the Administrative Safeguard Standard (Information Access Management). This implementation specification is required. What to Do If a healthcare clearinghouse is part of a larger organization, the clearinghouse must implement policies and procedures that protect the electronic protected health information of the clearinghouse from unauthorized access by the larger organization. Remember, a clearinghouse is defined as a covered entity, but also can serve in the role of a business associate to other covered entities, namely a health plan or healthcare provider. How to Do It This implementation specification is required, but is not likely…

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Information Access Management-What This HIPAA Security Rule Administrative Safeguard Standard Means

This is the fourth Administrative Safeguard Standard of the HIPAA Administrative Simplification Security Rule. It has three implementation specifications: Isolating Healthcare Clearinghouse Functions; Access Authorization; and Access Establishment and Modification. The first is required; the second and third 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 we noted in a posting last week, with enactment of the American Recovery and Reinvestment Act of 2009 on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. The covered entity is…

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Security Management Process: Sanction Policy-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 (Security Management Process). This implementation specification is required. What to Do Apply appropriate sanctions against workforce members who fail to comply with the security policies and procedures of the covered entity. How to Do It The covered entity must determine appropriate internal sanctions or penalties for violation of its security policies and procedures by workforce members. Sanctions should: » Deter noncompliant behavior, such as posting passwords on computer hardware or under a desk pad. » Serve as an incentive for compliance with security policies and procedures. The appropriate sanctions…

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