Overwhelmed by HIPAA? Compliance is a Process, Not an Event

Like most major change initiatives, HIPAA compliance doesn’t happen in a day. It requires change by every person in the organization. Everyone who touches PHI (protected health information) must develop new work habits to keep PHI secure…Staff who answer phones, schedule appointments, and check patients in have to maintain patient confidentiality in very public work stations…IT staff must implement new technical safeguards and continually monitor systems…Managers must learn the new roles of P ...

HHS OCR: PHI Security is your top priority

If you haven't noticed, cybersecurity is a major issue in the world, politically, economically, and even personally.  No one wants their identity stolen.  No business wants to deal with customer (patient) retaliation caused from losing their personal health information, whether it's boycotting, bad press, negative social media or a class action lawsuit. In general the U.S. government is taking action to help protect small businesses by requesting a new standard cybersecurity guide be written by the Nat ...

Missing the Target of HIPAA – Part 3

If you haven't read my previous two blogs on this topic I encourage you to do so.  The first blog stresses the importance of being risk management proficient over being a HIPAA “expert”. The second blog deals with being accountable in your work actions, which means not only are you responsible for your actions, but your actions can be independently verified.  These two “factors” can go a long way to protecting your organization from the risks of a breach and from substantial penalties and fine ...

Why your Meaningful Use SRA is not enough

Many covered entities had a high level Security Risk Analysis (SRA) performed to "check the box" for meeting the Meaningful Use requirement.  The HHS OCR has now performed enough audits, however, to know that a risk assessment isn't enough - Covered Entities need to take corrective action. With MACRA and HIPAA both requiring an SRA and HIPAA requiring a prioritized list of risks, corrective action plans, and a risk management process, it's time to have a proper risk assessment performed and take cor ...

Missing the HIPAA Target – Part 2

In my previous blog, I stressed compliance is not about being an expert on HIPAA regulations, but being risk management proficient ― the ability to identify vulnerabilities and threats facing your organization, and to take steps to eliminate, minimize or manage them.  I usually refer to the next step as "ownership", but I’m not really a fan of the term.  A common synonym is "possession".  You can own something, but it doesn’t mean you are committed to taking care of it or ensuring a positive ou ...

One small step for man, one giant leap for privacy!

“To err is human”… a pretty obvious statement. So if we all know we are going to make mistakes, why not add an extra level of security to mitigate the effects of the mistake? I am sure we have all been in the predicament of sending John C. an email, but when we clicked on our contacts list we accidentally sent it to John B. I have conversations constantly with clients and friends about encrypting their email to protect themselves and often get the same set of questions… “Isn’t that e ...

Missing the Target of HIPAA

Universally when working with new clients, they tell me, “I can’t learn all these HIPAA regulations and requirements.  I don’t have the time or the desire to be an expert on HIPAA!”  My response is, “That is absolutely correct!  You shouldn’t be an expert on HIPAA; that is my job.  What you and all your staff should be is risk management proficient.” Most times that draws the deer-in-the-headlights stare.  Not much comfort is taken from my response. Usually the conversation proceed ...