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…)
Archive for the ‘Privacy and Compliance’ Category
Preliminary Thoughts about the HIPAA Accounting of Disclosures NPRM
Tuesday, May 31st, 2011Yes, Automating Compliance Activities Can Improve Security…If Done Correctly!
Tuesday, March 8th, 2011I 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…)
HIPAA: It is About the Information!
Friday, February 4th, 2011NOTE: This is a repost for those that have browsers that could not open the original. Hopefully this will fix the problem!
Over the years I’ve had a lot of organizations ask me about whether HIPAA applies to faxes, copy machines, and other types of specific technologies. It is very important that covered entities (CEs), business associates (BAs) and their subcontractors understand that HIPAA applies to protecting the information! It doesn’t matter what the conduit is for how the information is transmitted, or where it is stored or accessed from. The important point is that protected health information (PHI), in all forms, must be protected. The Security Rule applies to only electronic data, but the Privacy Rule and HITECH apply to all forms of PHI. Okay; let’s keep this in mind when considering the following question I got earlier this week from a HIPAA business associate…
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HIPAA: It’s About the Information!
Friday, February 4th, 2011Over the years I’ve had a lot of organizations ask me about whether HIPAA applies to faxes, copy machines, and other types of specific technologies. It is very important that covered entities (CEs), business associates (BAs) and their subcontractors understand that HIPAA applies to protecting the information! It doesn’t matter what the conduit is for how the information is transmitted, or where it is stored or accessed from. The important point is that protected health information (PHI), in all forms, must be protected. The Security Rule applies to only electronic data, but the Privacy Rule and HITECH apply to all forms of PHI. Okay; let’s keep this in mind when considering the following question I got earlier this week from a HIPAA business associate… (more…)
HIPAA Compliance Investigations And The Insider Threat
Wednesday, February 2nd, 2011I’ve been getting a lot more questions about HIPAA and HITECH lately from folks I’ve never met, but who have concerns about the security and privacy of their health information (“protected health information” or “PHI” as referenced within HIPAA/HITECH), businesses that are trying to understand how to protect PHI according to the regulatory requirements, and a growing number who express frustration with the unsecure ways in which clients, customers, patients and business partners are sharing information with them. There just are not enough hours in the day to answer them all, but I decided I’d start sharing some of the questions, and my corresponding answers, that seem to be topics that a wide range of readers may be interested in.
I was recently contacted by someone who had a question about a recent HIPAA complaint against Rowan Regional Medical Center (more…)
HIPAA/HITECH Final Rule Set To Be Published in March
Tuesday, January 4th, 2011On December 20, 2010, the U.S. federal government published “Part II: Regulatory Information Service Center: Introduction to The Regulatory Plan and the Unified Agenda of Federal Regulatory and Deregulatory Actions.” If you are a healthcare Covered Entity (CE), Business Associate (BA) or BA subcontractor, as defined under HIPAA and HITECH, this should be of interest to you. Why? Because within it is the long-awaited Department of Health and Human Services (HHS) timeline for when they would publish the final rule of the Notice of Proposed Rule Making (NPRM) that came out in July, 2010. The date? Well, (more…)
Reining In Mobile Computing Risks
Sunday, October 3rd, 2010As demonstrated over and over again over the past several years, mobile computing devices and storage media present a huge risk to business and personal information. Because of the portability of these devices, organizations are basically entrusting the security of the information stored upon them into the hands of the people using them. It is vital that an effective mobile computing device and storage media security and privacy management program is in place.
A mobile computing device and storage media security and privacy management program should be able to answer the questions: (more…)
Smart Grid Privacy: Possible Privacy Standards To Address Concerns
Saturday, November 28th, 2009Sorry to be so tardy in getting a blog post out. As many of you know I’ve been working with the NIST Smart Grid Privacy Subgroup since late June. The work done for this group is through time volunteered by all involved.
As a quick recap, I led the privacy impact assessment (PIA) for the consumer-to-utility portion of the planned smart grid during the late June to late August/early September time frame. On Friday, 11/20, I provided an update on our NIST groups activities during the Gridwise Alliance phone conference; perhaps some of you were on that call?
Here are some links showing information about our NIST Smart Grid privacy group’s work:
