Matthew Fisher, ESQ and Jonathan Krasner Healthcare represents a very large segment of our economy – approaching 20% by some estimates. As such, healthcare organizations come in many sizes and flavors. We are all, hopefully, familiar with the basics that HIPAA compliance requirements apply Covered Entities, Business Associates and subcontractors. A CE and a BA...
HIPAA is often described as dealing with CIA – the Confidentiality, Integrity and Access to patient records. In the past, access to patient records often required a written request, accompanied by a response in the mail that could take several weeks. However, in today’s world where electronic systems can provide almost instant action to data,...
HIPAA data breaches can occur if ePHI (electronic protected health information) is posted on an open web site. In that situation, not only is the ePHI available for viewing, it also can be indexed by an Internet search engine such as Google. Many data breaches have been uncovered by finding the unauthorized ePHI via...
Federally Qualified Health Centers (FQHCs), Community Health Centers (CHCs) and related entities are non-profit organizations that run on shoestring budgets. These organizations are constantly in search of revenue, grants and donations to keep their operations running. Therefore, any type of adverse financial event will be devastating. However, these organizations also must comply with relevant regulations,...
Pun intended. We all use cloud computing resources every day. All you have to do is go on the Internet, and chances are the website you are accessing uses cloud services. Our website, www.hipaasecurenow.com, uses the Amazon cloud. There are many definitions of cloud services, but at a high level it is the use of...
Back in March, we reported that OCR had announced its Phase 2 Audit Program. When we last heard from OCR about Phase 2 HIPAA Audits, we saw that emails were being sent to Covered Entities and Business Associates. The purpose of the emails was to verify and expand the OCR HIPAA audit pool. We wrote...
By now we are all aware of the horrible event that took place in Orlando over the weekend. Mass casualties caused local hospitals and ERs to respond heroically. One of the tasks required during these operations was the necessity to communicate patient status with family and loved ones. Unfortunately, this was not handled very well....
Back in March, we reported that OCR had announced its Phase 2 Audit Program. OCR stated that they would compile a database of both Covered Entities and Business Associates to form the basis of the pool of organizations potentially targeted for audit. They have followed up on their intentions and in the last week organizations...
On April 27, CMS came out with a proposed rule on how physicians will get paid under MACRA (the Medicare Access and CHIP Reauthorization Act). If you want to read the whole 962 page snoozefest, you can find it here (PDF). But sleep or not, this regulation changes the fundamental Fee-For-Service (FFS) system that CMS...
Background Although HIPAA is an important set of laws passed to protect the sensitive medical information handled by millions of covered entities and business associates, Health and Human Services Office for Civil Rights (OCR) has never established a permanent compliance audit program. Auditing activity to date by OCR has consisted of a pilot program of...
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