Evaluation-What This HIPAA Security Rule Administrative Safeguard Standard Means

This is the eighth Administrative Safeguard Standard of the HIPAA Administrative Simplification Security Rule. Its implementation specification is embodied in the language of the standard itself, and it is required of covered entities.  Further, as HIPAA.com has noted earlier, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010, as provided for in the HITECH Act provisions of the American Recovery and Reinvestment Act, signed by President Obama on February 17, 2009. What is Required Perform a periodic technical and non-technical evaluation, based initially upon the standards implemented under this rule and subsequently, in response to environmental or operational changes affecting the security of…

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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: 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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Contingency Plan-What This HIPAA Security Rule Administrative Safeguard Standard Means

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. If a fire swept through a covered entity’s facility, the covered entity would…

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What should you expect from your HIPAA Security Official?

HIPAA’s Security Rule requires covered entities to designate one person to be responsible for the development and implementation of policies and procedures that safeguard electronic protected health information. Nearly all organizations implemented measures to manage privacy in oral, written, and electronic media. However, as healthcare organizations and their business associates, inspired by the HITECH Act (stimulus package) respond to forthcoming financial incentives to adopt electronic health record (EHR) software, the need to beef up your security measures. So what should you look for in your Security Official? For starters, you need someone who understands clinical and billing workflows, recognizes that in the past some clinicians have communicated with patients via…

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Information Access Management: Access Establishment and Modification-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 (Information Access Management). 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. Further, as we have 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. What to Do Implement policies and procedures that, based upon the covered entity’s…

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Information Access Management: Access Authorization-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 (Information Access Management). 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.  Further, as we have 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. What to Do Implement policies and procedures for granting access to electronic protected…

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