The April 2009 issue of Baseline magazine has an article by Corinne Bernstein entitled: “The Cost of Data Breaches,” which is available online at www.baselinemag.com. We recommended that covered entities and business associates review this article, based on a Ponemon Institute study of incidents and costs incurred at 43 organizations in 17 industry sectors. Here are several highlights: » “Lost business accounted for nearly 70 percent of a data breach in 2008. » “[S]ectors suffering the highest customer losses were health care…and financial services. » “The biggest cause of breaches…is insider negligence…88% of all cases in 2008. » “The number of breaches involving third-party organizations continues to climb.” The article…
Month: April 2009
Word of the Day: EHR
Electronic health record (EHR): A secure, real-time, interoperable point-of-care, patient-centric information resource for clinicians. The EHR aids clinicians in decision making by providing access to patient health record information where and when they need it and by incorporating evidence-based decision support. The EHR automates and streamlines the clinicians’ workflow, closing loops in communication and response that result in delays or gaps in care. The EHR also supports the collection of data for uses other than direct clinical care, such as billing, quality management, outcomes reporting, resource planning, and public health disease surveillance and reporting.
Kudos to DOQ-IT
Praise goes out to the Doctors Office Quality – Information Technology (DOQ-IT) centers that worked tirelessly to assist physicians select and implement electronic health records. Effective April 16, 2009, DOQ-IT will end. Access to all DOQ-IT-related programming and resources on QualityNet (e.g., online registration, data submission, reports) will end April 16, 2009, at 5 p.m. Central Time. We have had the pleasure of working with most of the DOQ-IT program leaders, building substantial friendships. We hope that their work will be a strong impetus to build on as physicians continue to select, implement and thrive in a health IT environment.
Contingency Plan: Applications and Data Criticality Analysis-What to Do and How to Do It
In our series on the HIPAA Administrative Simplification Security Rule, this is the fifth implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is addressable. Remember, addressable does not mean “optional.” Rather, an addressable implementation specification means that a covered entity must use reasonable and appropriate measures to meet the standard. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Assess the relative criticality of specific applications and data in support of other…
Contingency Plan: Testing and Revision Procedures-What to Do and How to Do It
In our series on the HIPAA Administrative Simplification Security Rule, this is the fourth implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is addressable. Remember, addressable does not mean “optional.” Rather, an addressable implementation specification means that a covered entity must use reasonable and appropriate measures to meet the standard. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Implement procedures for periodic testing and revision of contingency plans. How to Do…
Contingency Plan: Emergency Mode Operation Plan-What to Do and How to Do It
In our series on the HIPAA Administrative Simplification Security Rule, this is the third implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is required. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Establish (and implement as needed) procedures to enable continuation of critical business processes for protection of the security of electronic protected health information while operating in the emergency mode. How to Do It Covered entities are required to develop…
Contingency Plan: Disaster Recovery Plan-What to Do and How to Do It
In our series on the HIPAA Administrative Simplification Security Rule, this is the second implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is required. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Establish (and implement as needed) procedures to restore any loss of data. How to Do It The content and procedures of a covered entity’s disaster recovery plan will be » Outcomes of the covered entity’s identification of vulnerabilities and…
Direct Data Entry-No Change in the 5010 Final Rule
In the August 17, 2000 Final Rule for Standards for Electronic Transactions, direct data entry was defined as “direct entry of data (for example, using dumb terminals or web browsers) that is immediately transmitted into a health plan’s computer.” [65 Federal Register 50367] An exception for direct data entry was articulated in the August 17, 2000, Final Rule: A health care provider electing to use direct data entry offered by a health plan to conduct a transaction for which a standard has been adopted under this part must use the applicable data content and data condition requirements of the standard when conducting the transaction. The health care provider is not…
Contingency Plan: Data Backup-What to Do and How to Do It
In our series on the HIPAA Administrative Simplification Security Rule, this is the first implementation specification for the Administrative Safeguard Standard (Contingency Plan). This implementation specification is required. As HIPAA.com has noted in earlier postings, with enactment of the American Recovery and Reinvestment Act of 2009 (ARRA) on February 17, 2009, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. What to Do Establish and implement procedures to create and maintain retrievable exact copies of electronic protected health information. How to Do It Covered entities must backup electronic protected health information on a regular basis. When a computer system fails, it may…
Contingency Plan: Sample Policy and Procedures
This is the seventh Administrative Safeguard Standard of the HIPAA Administrative Simplification Security Rule. It has five implementation specifications: Data backup plan; Disaster recovery plan; Emergency mode operation plan; Testing and revision procedures; and Applications and data criticality analysis. The first three are required; the last two are addressable. Addressable does not mean optional. Rather, an addressable implementation specification means that a covered entity must use reasonable and appropriate measures to meet the standard. Further, as HIPAA.com has noted earlier, business associates also will be required to comply with the Security Rule standards, effective February 17, 2010. HIPAA.com will outline What to do and How to do it for each…