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 ...

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