Archive for the ‘HIPAA’ Category

HIPAA/HITECH Compliance Is All or Nothing

Tuesday, August 16th, 2011

I’m seeing growing numbers of  business associates, particularly those who do technology-based services, expressing the belief that they don’t need to worry about complying with most of HIPAA.  I wrote a guest blog post for Credant about this misguided thinking that was published today.  I welcome your feedback!

KPMG HIPAA Auditor Caused a Data Breach

Tuesday, August 9th, 2011

A KPMG auditor caused a breach for New Jersey hospitals because he or she lost an unencrypted flash drive containing over 4,500 patient records. (more…)

UCLA Health System Pays $865K to Settle Celebrity Privacy HIPAA Violations

Friday, July 8th, 2011

Here’s yet another HIPAA violations penalty to add to what seems to be a quickly growing list.  In this case it was a violation of the minimum necessary access principle, in addition to providing the information to reporters, who then published the information.  And, it is likely based upon the required actions that go beyond the fine, that the policies, procedures, training, awareness, and access logging processes was lacking as well. (more…)

10 Risk-Reducing Actions for Mobile HIPAA/HITECH Compliance

Sunday, June 19th, 2011

I’m giving a free webinar sponsored by Sophos this coming Wednesday, June 22: “10 Risk-Reducing Actions for Mobile HIPAA/HITECH Compliance.”   Here is more information about it: (more…)

Designated Record Sets: Know What They Are! (AD NPRM Discussion #1)

Thursday, June 2nd, 2011

My last blog post provided a preliminary overview of the Accounting of Disclosures Notice of Proposed Rulemaking (AD  NPRM).  I got a lot of questions as a result directly, in addition to the blog comments. When trying to understand regulations, and how to put them into practice within an organization, I’ve found it is best to break them down into bite-sized chunks, starting from the basics and building from there.  Today I want to spend a little time looking at what makes up a “designated record set,” or DRS, since the access report requirement is specific to accesses to DRS’s… (more…)

Preliminary Thoughts about the HIPAA Accounting of Disclosures NPRM

Tuesday, May 31st, 2011

On Friday, May 27, 2011, the Department of Health and Human Services (HHS) published the HIPAA Privacy Rule Accounting of Disclosures under the Health Information Technology for Economic and Clinical Health Act Notice of Proposed Rule Making (NPRM).  I’m still going through it but here are my preliminary thoughts… (more…)

Physician Learns A Hard PHI Lesson

Tuesday, April 19th, 2011

News broke  yesterday about a physician in Rhode Island, at the Westerly Hospital, who was sanctioned for posting protected health information (PHI) on her Facebook page: (more…)

Health Net Incident Impacting 1.9 Million: Lessons Learned

Wednesday, April 6th, 2011

Yesterday I provided some thoughts to Howard Anderson at HealthinfoSecurity.com about the recent Health Net incident for his article Here are some expanded thoughts for his questions…

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Legal Requirements for Information Security and Privacy Awareness and Training

Wednesday, March 30th, 2011

Earlier today following my online seminar, “Effective Training and Awareness: The Key to Information Security Success”  (http://gocsi.com/Training2011/OD/Awareness), I received the following question: 

 Where might I locate a summary breakdown of training regulations by industry? i.e. Pharma 

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Yes, Automating Compliance Activities Can Improve Security…If Done Correctly!

Tuesday, March 8th, 2011

I participate in the Focus network and tried to answer the following question from “Caty” on their discussion board:

“How can compliance automation help secure my organization’s IT infrastructure?” Please describe the benefits of compliance automation and discuss how it can be used to secure an organization’s IT infrastructure.

However, after trying to submit my response in around half a dozen ways, I was told my answer was too long.  Instead of shaving off some of my content, I decided to post here to my blog, and then point to here from there.  Perhaps my other blog readers will be interested in my thoughts on this topic as well.

So, here is my answer… (more…)