Posts Tagged ‘HIPAA’
Thursday, January 24th, 2013
The final HIPAA “mega rule” is going to be officially published on the Federal Register tomorrow, January 25, 2013. Currently the version available (https://s3.amazonaws.com/public-inspection.federalregister.gov/2013-01073.pdf) is “pre-publication” version.
Over the past week I’ve had numerous CEs and BAs contacting me, frantic to change their BA Agreements to “avoid complying with the Mega Rule for another year!” Wait, folks. You are misunderstanding; this is a very specific extension that only applies to the BA Agreements. Let me explain… (more…)
Tags:BA, BA Agreement, business associate, compliance, Compliance Helper, covered entity, federal register, Final Rule, healthcare, herold, HHS, HIPAA, HITECH, Information Security, Mega Rule, OCR, privacy, privacy professor, Rebecca Herold, security
Posted in BA, CE, HIPAA, HITECH | No Comments »
Friday, December 21st, 2012
This week I spoke with a small (~25 employees) organization (a business associate providing services to healthcare providers) that contacted me looking for help; they had purchased a whiz-bang “HIPAA compliance GRC” solution that included with everything else information security policies, but they couldn’t make any sense of the policies they were given or how they related to the rest of the expensive GRC tool. Grrr!! There are (more…)
Tags:audit, audits, awareness, BA, breach, business associate, business partner, CE, compliance, covered entity, customers, data protection, e-mail, electronic mail, email, employees, employment, HIPAA, hiring, HITECH, HR, human resources, IBM, Information Security, information technology, infosec, IT security, job applicants, laws, messaging, midmarket, non-compliance, patients, personal information, personally identifiable information, personnel, PII, policies, privacy, privacy breach, privacy professor, privacyprof, procedures, Rebecca Herold, risk, risk assessment, risk management, security, sensitive personal information, SPI, systems security, training, walk through
Posted in BA, CE, HIPAA, Information Security | 1 Comment »
Wednesday, November 21st, 2012
Growing numbers of organizations are trying to figure out the benefits of anonymizing, or as HIPAA (the only regulation that provides specific legal requirements for such actions) puts it “de-identifying,” personal information. Healthcare organizations see benefits for improving healthcare. Their business associates (BAs) see benefits in the ways in which they can minimize the controls around such data. Of course marketing organizations salivate at the prospects of doing advanced analysis with such data to discover new trends and marketing possibilities. The government wants to use it for investigations. Historians want to use it for, yes, marking historical events. And the list (more…)
Tags:anonymization, anonymized, audit, awareness, BAs, breach, CEs, compliance, customers, data protection, de-identificaiton framework, de-identification, de-identify, e-mail, electronic mail, email, employees, employment, Herold de-identification, HHS, HIPAA, hiring, HITECH, HR, human resources, IBM, Information Security, information technology, infosec, IT security, job applicants, laws, messaging, midmarket, non-compliance, OCR, patients, PbD, personal information, personally identifiable information, personnel, PHI, PII, policies, privacy, privacy breach, Privacy by Design, privacy professor, privacyprof, Rebecca Herold, reputation, risk, security, sensitive personal information, SPI, systems security, training
Posted in HIPAA, privacy, Uncategorized | No Comments »
Wednesday, October 31st, 2012
Last week I got the following question:
“By becoming ISO 27001 certified does that automatically mean we comply with HIPAA and HITECH requirements? Are there any requirements of HIPAA/HITECH that are not required to meet ISO 27001 standards?”
This is not the first time I’ve gotten this question, and others similar. As new technology businesses, cloud services and other businesses are popping up to provide services to large regulated organizations, start-ups are increasingly looking for a way to differentiate themselves from their competitors, and also prove that they have not only effective security controls in place, but that they also (more…)
Tags:27001, 27002, audit, awareness, breach, certification, compliance, customers, data protection, e-mail, electronic mail, email, employees, employment, HHS, HIPAA, hiring, HITECH, HR, human resources, IBM, Information Security, information technology, infosec, ISMS, ISO27001, ISO27002, IT security, job applicants, laws, messaging, midmarket, non-compliance, OCR, patients, personal information, personally identifiable information, personnel, PII, policies, privacy, privacy breach, privacy professor, privacyprof, Rebecca Herold, reputation, risk, security, sensitive personal information, SPI, systems security, training
Posted in HIPAA, HITECH, Laws & Regulations | No Comments »
Wednesday, June 27th, 2012
July 4 Update to Original Post: See additional recent statements from the OCR and the Alaska DHSS about this case here.
Here is a significant sanction, just applied, that all organizations, of all sizes, need to take notice of. Even if you are not in the healthcare industry, this case points out the elements of an information security and privacy program, and the supporting safeguards, which will be used as a model of standard practices to by all types of regulatory oversight agencies. (more…)
Tags:Alaska, audit, awareness, breach, compliance, fine, HHS, HIPAA, IBM, Information Security, information technology, infosec, IT security, Medicaid, midmarket, non-compliance, OCR, personal information, personally identifiable information, PHI, PII, policies, privacy, privacy breach, privacy professor, privacyprof, Rebecca Herold, risk assessment, sanction, security, sensitive personal information, SPI, systems security, training
Posted in government, healthcare, HIPAA, HITECH | No Comments »
Friday, March 2nd, 2012
I am looking forward to the day when we can look at the news headlines and not see some report about a lost or stolen computing device or storage device that contained unencrypted personal information and/or other sensitive information. And, I also want to stop seeing stories reappear about such an incident, such as the stolen NASA laptop with the clear text Space Station control codes that was stolen last year, but is making the headlines yet again today. NASA is a large enough, and tech savvy enough, organization to know better! However, there are many organizations that simply don’t understand what a valuable information security tool encryption is. I work with many small to medium sized businesses (SMBs), all of which have legal obligations (such as through HIPAA and HITECH, along with contractual requirements) to protect sensitive information, such as personal information. Over the past year I’ve heard way too many of them make remarks such as… (more…)
Tags:BA, business associate, CE, covered entity, encrypt, encryption, HIPAA, HITECH, IBM, medium business, midmarket, PHI, privacy, privacy professor, privacy rule, privacyprof, protected health information, Rebecca Herold, safeguards, security, security rule, small business, SMB, W-2, W2
Posted in Information Security | 1 Comment »
Monday, February 27th, 2012
“Is a W-2 form protected health information?” is a simple question with a complex answer that begins (I know, to the nail-biting chagrin of many), “It depends…”
First the full question: (more…)
Tags:BA, business associate, CE, covered entity, HIPAA, HITECH, IBM, midmarket, PHI, privacy, privacy professor, privacy rule, privacyprof, protected health information, Rebecca Herold, safeguards, security, security rule, W-2, W2
Posted in BA, CE, HIPAA, HITECH | No Comments »
Tuesday, January 3rd, 2012
Happy New Year! I hope your year is starting out great. Have you made it to day 3 without breaking any of your resolutions? How about adding one more… (more…)
Tags:awareness, compliance, education, HIPAA, Information Security, personal information, PHI, PII, privacy, privacyprof, Rebecca Herold, training
Posted in privacy, Training & awareness | No Comments »
Saturday, December 10th, 2011
On October 10, 2011, there was a report in the Baltimore Sun, “Law firm loses hard drive with patient records: Attorneys represent St. Joseph cardiologist sued for malpractice.” I posted about the report to one of the LinkedIn groups I participate in, pointing out that this is yet one more example of (more…)
Tags:BA, Baltimore, business associate, cardiologist, CE, compliance, covered entity, HIPAA, HITECH, hospital, Information Security, lawyer, malpractice, PHI, privacy, privacy breach, Rebecca Herold, St. Joseph, subpoena
Posted in BA, CE, healthcare, HIPAA, HITECH, Information Security, Laws & Regulations, privacy, Privacy and Compliance | 6 Comments »
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…)
Tags:accounting of disclosures, BA, business associates, CE, covered entities, herold, HHS, HIPAA, HITECH, Information Security, notice of proposed rule making, NPRM, OCR, privacy, privacy breach, privacy rule, sanctions, security, security rule, UCLA
Posted in CE, healthcare, HIPAA, HITECH, Information Security, Laws & Regulations, Non-compliance Sanctions Examples, privacy, Privacy and Compliance, Privacy Incidents | 4 Comments »
