Could this breach have been prevented? – A new series

Could this breach have been prevented? – A new series One of the first lessons of process improvement is that preventing errors is much less expensive and time-consuming than remedying the damage after the fact. The same is true for an information breach. The time and cost for installing new software, training staff members, and reinforcing policies and procedures pales in comparison to cleaning up the damage of an information privacy or security breach. Recent headlines of multi-million-dollar ...

Thank Goodness! NIST says, “No more difficult passwords!”

Just when you thought all hope was lost of remembering your 16 character password with upper and lower case letters, numbers, and special characters; NIST comes to the rescue. That's right!  The National Institute of Standards and Technology wrote a brief addendum to SP 800-53 which simplifies Strength of Memorized Secrets.  You and I refer to those "secrets" as passwords.  It's a light read, only 50 or 60 pages.  I don't really know because I didn't want to print it and kill four trees.  Anyway, the ...

What happens when someone submits a HIPAA complaint?

You may not realize how easy it is for someone to submit a complaint about your organization. However, if you are not prepared, what happens after that submission is not something you will soon forget! This is why HIPAA compliance must be a culture and not just a piece of paper. While someone WILL submit a complaint against you at some point, if you have a culture of compliance in place, there should be little to no effect on your business. If you just run through a simplified checklist once a year, howeve ...

An Ounce of Prevention – Why HIPAA Guidelines should be your standard operating procedures

The American Heart Association lists heart disease as the #1 cause of death in the US with nearly 800,000 deaths per year. In comparison, more than 3.1 million patients have been impacted in the first half of 2017 by a data breach that led to the theft of protected health information (PHI). That's right — in half the time, nearly four times as many people have been impacted by an information breach as have died from heart disease! Yet an estimated two thirds of medical practices remain at risk of bei ...

Focus on Security: In plain sight

Sometimes we tend to focus strictly on the technical side of security and compliance and fail to notice the very important issues hiding in plain sight. While a hacker breaking into your network and stealing ePHI is the threat that is being talked about the most, it is sometimes the overlooked old-fashioned threats that present the greater risk. Think about how many times a patient record has been sitting somewhere and how long does it actually take for someone to pick it up and walk off? What about allo ...

HIPAA – Standard Operations for Business

HIPAA gets a bad rap - and deservedly so. However, most of that bad rap is because it is set up in a typical government fashion that is hard to understand and make sense of. When you look at the HIPAA laws and guidelines, it is not long before you become more perplexed than you were before. However, once you get past the government's idea of light reading, or by using our CompassDB tool which translates it into a humanly readable language, you realize that the HIPAA guidelines are not really all that cu ...

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 ...

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 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 ...

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