Bringing Box into HIPAA Alignment. Bob Flynn & Anurag Shankar University Information Technology Services Indiana University

Size: px
Start display at page:

Download "Bringing Box into HIPAA Alignment. Bob Flynn & Anurag Shankar University Information Technology Services Indiana University"

Transcription

1 Bringing Box into HIPAA Alignment Bob Flynn & Anurag Shankar University Information Technology Services Indiana University

2 Outline 1. Introduction 2. Service Partnership 3. Legal Requirements 4. Risk Management Framework 5. Box Evaluation 6. Conclusions

3 1. Introduction

4 Nature abhors a vacuum! The lack of HIPAA compliant campus services that support external collaborations is forcing biomedical researchers to share sensitive data using and cloud services such as Google docs, Dropbox, etc.

5 HIPAA in the Cloud? The lure of free or cheap cloud storage is irresistible, even for HIPAA regulated entities. Cloud providers have been unaware or unwilling to address HIPAA compliance, but... Market pressures are forcing many vendors to reconsider HIPAA. Chief among these are Amazon, Microsoft, and now Box. We at IU have also been revisiting our stance of keeping our sensitive data out of the cloud, specifically as regards Box.

6 Current Regulatory Climate With growing security threat, (Governance, Risk, and) Compliance is now the new frontier for IT. If you handle biomedical data, you not only face HIPAA, but possibly FISMA also. Recent changes to HIPAA have put more teeth into enforcement = more motivation for us.

7 Recent HIPAA Changes A new HIPAA Omnibus Rule was enacted in It adds new requirements for a business associate (BA) who handles your sensitive data. It greatly ramps up civil penalties. The government will initiate random HIPAA audits in (They were triggered only in response to a breach earlier.)

8 2. Service Partnership

9 & HIPAA Implemented at IU in 2012, Box became wildly popular for sharing data with collaborators within and outside IU. Researchers in the IU School of Medicine (second largest medical school in the U.S.) soon wanted to use Box to share clinical data. (Biomedical research grants from NIH require data sharing.) Since identifiable clinical research data is subject to HIPAA, we asked Is Box HIPAA compliant?

10 Box & HIPAA In 2013, Box began talking about the possibility of HIPAA alignment after conducting thirty party security and HIPAA audits. In late 2013, they began signing contracts promising to comply with HIPAA. Internet2 has negotiated a BAA and revised contract with Box.

11 IU Basics 8 Campuses (2 Core, 6 Regional) 115K Students, 20K Faculty/Staff 1.3M Credit Hours (Fall 2013) $533M in external research funding (2012) Strong Central IT and good partnership with distributed IT operations.

12 Basics Program rollout April 2012 Reached 50,000 users by October 2013 Currently 64,000 internal users 7,000 external collaborators 120,000 collaborations 50TB in storage All this without FERPA or HIPAA data

13 Basics

14 3. Legal Requirements

15 HIPAA Health Insurance Portability & Accountability Act, passed in 1996, became law in Enforced by the Office for Civil Rights (OCR) in the U.S. Dept. of Health & Human Services (HHS). Modified in 2013 by including provisions from the 2006 Health Information Technology for Economic & Clinical Health (HITECH) Act & the 2008 Genetic Information Nondiscrimination Act (GINA). Consists of the HIPAA Privacy Rule and the HIPAA Security Rule.

16 The HIPAA Security Rule The Security Rule regulates electronic protected health information* (ephi). It requires (1) administrative, (2) physical, and (3) technical safeguards to Ensure the confidentiality, integrity, and availability of all ephi created, received, maintained or transmitted; Identify and protect against reasonably anticipated threats to the security or integrity of the information; Protect against reasonably anticipated, impermissible uses or disclosures; Ensure compliance by the workforce; and Provide a means for managing risk in an ongoing fashion. * Data with one or more of 18 patient identifiers such as name, DOB, etc.

17 The HIPAA Security Rule

18 Covered Entities & Business Associates Healthcare providers, health plans, and health clearinghouses are called HIPAA covered entities. Universities are often hybrid covered entities, with covered components that do healthcare and components that are not covered. If you serve a covered component within your organization, chances are that you too are covered. If you are not part of a covered entity but handle their data, you are a business associate (BA). In the Box context, you are a covered entity and Box is a BA.

19 Security Rule Safeguards Administrative security organization, policies, training, responsibilities, incident response, etc. Physical data center access, equipment/ media disposal, inventory control, etc. Technical firewalls, patching, auditing, scanning, monitoring, accounts, etc. + organizational/policies/documentation requirements

20 Required & Addressable Each Security Rule safeguard is either required or addressable. Required = what it says. Addressable = should address, but ok if you describe why it is not in place or how you will otherwise address the risk. A risk assessment (RA) identifies where to concentrate mitigation effort.

21 Breach Notification HIPAA requires that a breach of ephi be reported ASAP: 1. To everyone whose privacy is breached. 2. For breaches affecting > 500 patients, to the media and the Secretary of the U.S. Dept. of Health & Human Services. The BA must notify you if the breach occurs at their end.

22 Business Associates HIPAA requires a business associate agreement (BAA) with any external entity that touches your ephi. The BAA must include language that your BA & their BAs will protect your ephi. Due diligence also means ensuring that the BA is capable of protecting your ephi in conformance with HIPAA.

23 Enforcement HIPAA violations can result in civil monetary penalties up to $1.5 million/violation against a HIPAA covered entity and/or individual criminal penalties up to10 yrs in jail. For large breaches, the OCR imposes a (potentially very expensive) corrective action plan (CAP). Random govt. HIPAA audits are coming this year.

24 The Corrective Action Plan (CAP) signed by Idaho State University ì Breaches reported by universities But the worst is being in the newspapers!

25 Is All Identifiable Health Data ephi? NO. Identifiable health data outside a healthcare context (e.g. what you upload to Google Health, Microsoft HealthVault) is not ephi. Only healthcare providers, facilities, and insurers are bound by HIPAA. Data, if properly de-identified, is not subject to HIPAA. If unsure, contact your HIPAA Compliance office!

26 Just Good Security? Q: So, the HIPAA Security Rule means we just need to provide good IT security? A: NO. The Security Rule is about managing risk, and security is only PART of that management. HIPAA requires ongoing administrative controls, training, governance, policies, formal review, etc.

27 HIPAA Security Rule Myths Myth #1 Security Rule compliance is a boolean. Truth: There is no threshold where you suddenly become compliant. Myth #2 You can be certified HIPAA compliant. Truth: No company or federal agency is authorized to certify you as being HIPAA compliant. (The only way to know for sure is to survive a HIPAA audit!) So you align with the HIPAA rules as best as you can and usually self assert compliance.

28 HIPAA Security Rule Myths Myth #3 Once compliant, you stay compliant. Truth: No. Compliance is an ongoing process; once started, it never stops so long as you have ephi. Myth #4 You must have an external third party do risk/security assessment. Truth: No. You can do them internally, so long as you follow accepted practices and document it all.

29 4. Risk Management Framework

30 HIPAA requires that you manage risk intelligently

31 Information Security Risk Management Identify, assess, prioritize, and mitigate risk to information security on an ongoing basis. Think in terms of managing risk, not plugging security holes. Risk = {Threat/Vulnerability x Likelihood x Impact} A big threat due to an existing vulnerability that is highly unlikely to be exploited/has little impact is low risk. You don t kill yourself over it.

32 Risk Management Framework You should have a mature, standards-based* RMF consisting of: Good governance = institutional security organization, policies, sanctions, enforcement Risk management = assessment, mitigation through appropriate physical, administrative, technical controls, documentation Review = regular monitoring, reviews, assessment, and mitigation Awareness and training * = NIST

33 Do I need an entire RMF even if I just want to align Box? YES! If there is a breach and an OCR audit, they will first look at your general HIPAA safeguards, not just what you do with Box. Penalties are often levied due to risk not being managed properly. Having an RMF in place is an essential prerequisite to any HIPAA compliance work.

34 Implementing the RMF at IU 1. Assign ownership 8. Get official blessing & advertize 2. Form partnerships 7. Create & execute risk management plan Follow NIST Standards 3. Inventory/ document 6. Assess risk 5. Perform gap analysis/fill gaps 4. Hire external consultant (Much of this is usually already in place at most places but not documented in a compliance-oriented form.)

35 1 Assign Ownership Dedicated resources commensurate with the scale. At IU, we spent around 1.5 FTE-year for the initial effort and 1.0 FTE on an ongoing basis. Assigned someone to lead the project. Empowered the leader to be able to do the job.

36 2 Form Partnerships Got to know all IU Compliance folks. Formed an oversight committee; put all stakeholders on it Compliance, Counsel, Information Security Office, Information Policy Office, School of Medicine CIO/Security Office, staff/ faculty, and central IT senior management.

37 3 Inventory/Document Spent a lot of time on developing a documentation strategy/format. Inventoried all assets, current policies and procedures, physical, administrative, and technical controls in place already. Consulted with line managers & key staff. Instituted a secure document management system (DMS).

38 Identify Dependencies Inventoried infrastructure pieces on which systems/services depend. This means identity management, messaging, the network, data centers, etc. on which the systems/services to be aligned depend. Included as many of them as we could.

39 4 Hire External Consultant* Asked IU Compliance folks for references. Got referred to a consultant from DC, who also serves on national HIPAA committees, etc. Consultant was given information about the organization, documentation, etc. Consultant visited IU a couple times to do in-person interviews. * = optional

40 5 Perform Gap Analysis The Gap Analysis (GA) measures gaps between actual security and what the HIPAA Security Rule requires. Involved on-site interviews. Consultant used the data to identify gaps. We received the GA report.

41 Fill Gaps Reviewed gap analysis report. Filled as many holes as we could, especially the serious ones. Updated documentation. Got everything ready for a risk assessment.

42 6 Assess Risk Everything done so far went into the risk assessment exercise. Submitted updated documentation and other information as requested to the external consultant. On-site interviews followed. Received a risk assessment report listing identified risks and risk scores.

43 7 Create a Risk Management Plan Reviewed risk assessment report. Addressed all risks and documented mitigation, reason for not mitigating, or alternatives. Submitted the RM plan to the external consultant for review. Modified RM plan as per consultant recommendations.

44 Execute Risk Management Plan Execution involved some short term actions that addressed many high/ medium risk items immediately. Instituted long term processes such as regular reviews, risk monitoring, risk avoidance strategies, etc. Documented everything (again)

45 8 Get Official Blessing & Advertize Submitted everything to the oversight committee. Received an official letter of approval from Compliance in January Advertized internally and targeted only IUSM researchers to avoid unnecessary attention.

46 Follow Standards We used the NIST information security standard since it is often used for complying with HIPAA and is the basis for FISMA. It put an official seal & added rigor to the process. We also looked at other standards such as ISO 27001, COBIT, etc.

47 NIST

48 HIPAA - Ongoing Semi-annual, internal reviews, documentation updates. Risk reassessment. External reviews every 5 years. Annual, mandatory HIPAA training in the HIPAA regulation, how it applies to us, and our policies and procedures, etc. Self-assertion process for new services requires risk analysis, risk mitigation, documentation, security screening, & training/reviews.

49 Future Expand the mature, standards-based NIST approach. Provide NIST-based risk and security assessment tools for units to do their own internal assessments. Centralize documentation. Establish baseline risk profile, evaluate risks, update continuously as risks change.

50 5. Box Evaluation

51 While Box said they were HIPAA compliant, due diligence (to us) meant evaluating whether Box meets the same NIST standards we follow ourselves.

52 Method We asked Box for documentation of their information security practices, audit reports, etc. We reviewed the documents thoroughly. We used the NIST HIPAA Security Rule Toolkit to answer nearly 1000 questions about Box s security/risk management practices. Some of these answers came from the Box documentation, some from Box s Compliance folks.

53 NIST HIPAA Security Rule Toolkit Questionnaire

54 Results Box satisfies > 95% of HIPAA Security Rule requirements. They have the necessary Required and Addressable safeguards in place. It helps greatly that they encrypt all data in transit and at rest for enterprise customers (i.e. us) and secure the encryption keys.

55 Current Status We are waiting on a HIPAA compliant BAA with Box. After a BAA is in place, we will submit the paperwork to the IU HIPAA Compliance Office to approve Box s suitability for storing ephi. After approval, we expect to make Box available to biomedical researchers as a HIPAA aligned collaboration tool.

56 6. Conclusions

57 Conclusions Cloud computing is imminent; be prepared. Box provides an ideal data sharing environment for biomedical researchers. Our own NIST based evaluation found Box to be capable of keeping our ephi secure. We are using our existing RMF to satisfy dependencies and ensure end to end security.

58 Conclusions Follow your own institutional process, but an institutional RMF is an essential pre-requisite. Implementing a RMF also provides resources that can be used to align with any current/future regulation. It also makes breaches less likely, lowering liability and the chance of damaging institutional reputation.

59 We are more than happy to help in any way we can

60 Resources The HIPAA Security Rule NIST : Guide to Implementing the HIPAA Security Rule NIST : Recommended Security Controls NIST A: Guide for Assessing Security Controls FIPS 200: Federal Systems Minimum Security Requirements NIST HIPAA Security Rule Toolkit IU HIPAA Documentation Templates ( us) IU HIPAA Risk Assessment Template ( us)

61 Contact Bob Flynn Anurag Shankar

HITRUST CSF Assurance Program You Need a HITRUST CSF Assessment Now What?

HITRUST CSF Assurance Program You Need a HITRUST CSF Assessment Now What? HITRUST CSF Assurance Program You Need a HITRUST CSF Assessment Now What? Introduction This material is designed to answer some of the commonly asked questions by business associates and other organizations

More information

Building a Risk Management Framework for HIPAA & FISMA Compliance

Building a Risk Management Framework for HIPAA & FISMA Compliance Building a Risk Management Framework for HIPAA & FISMA Compliance Anurag Shankar Center for Applied Cybersecurity Research Indiana University 2015 Technology Exchange October 6, 2015 Outline 1. Introduction

More information

Understanding HIPAA Privacy and Security Helping Your Practice Select a HIPAA- Compliant IT Provider A White Paper by CMIT Solutions

Understanding HIPAA Privacy and Security Helping Your Practice Select a HIPAA- Compliant IT Provider A White Paper by CMIT Solutions Understanding HIPAA Privacy and Security Helping Your Practice Select a HIPAA- Compliant IT Provider A White Paper by CMIT Solutions Table of Contents Understanding HIPAA Privacy and Security... 1 What

More information

Ethics, Privilege, and Practical Issues in Cloud Computing, Privacy, and Data Protection: HIPAA February 13, 2015

Ethics, Privilege, and Practical Issues in Cloud Computing, Privacy, and Data Protection: HIPAA February 13, 2015 Ethics, Privilege, and Practical Issues in Cloud Computing, Privacy, and Data Protection: HIPAA February 13, 2015 Katherine M. Layman Cozen O Connor 1900 Market Street Philadelphia, PA 19103 (215) 665-2746

More information

Overview of the HIPAA Security Rule

Overview of the HIPAA Security Rule Office of the Secretary Office for Civil Rights () Overview of the HIPAA Security Rule Office for Civil Rights Region IX Alicia Cornish, EOS Sheila Fischer, Supervisory EOS Topics Upon completion of this

More information

Why Lawyers? Why Now?

Why Lawyers? Why Now? TODAY S PRESENTERS Why Lawyers? Why Now? New HIPAA regulations go into effect September 23, 2013 Expands HIPAA safeguarding and breach liabilities for business associates (BAs) Lawyer is considered a business

More information

Intelligent Vendor Risk Management

Intelligent Vendor Risk Management Intelligent Vendor Risk Management Cliff Baker, Managing Partner, Meditology Services LeeAnn Foltz, JD Compliance Resource Consultant, WoltersKluwer Law & Business Agenda Why it s Needed Regulatory Breach

More information

6/17/2013 PRESENTED BY: Updates on HIPAA, Data, IT and Security Technology. June 25, 2013

6/17/2013 PRESENTED BY: Updates on HIPAA, Data, IT and Security Technology. June 25, 2013 Updates on HIPAA, Data, IT and Security Technology June 25, 2013 1 The material appearing in this presentation is for informational purposes only and should not be construed as advice of any kind, including,

More information

White Paper THE HIPAA FINAL OMNIBUS RULE: NEW CHANGES IMPACTING BUSINESS ASSOCIATES

White Paper THE HIPAA FINAL OMNIBUS RULE: NEW CHANGES IMPACTING BUSINESS ASSOCIATES White Paper THE HIPAA FINAL OMNIBUS RULE: NEW CHANGES IMPACTING BUSINESS ASSOCIATES CONTENTS Introduction 3 Brief Overview of HIPPA Final Omnibus Rule 3 Changes to the Definition of Business Associate

More information

Data Security and Integrity of e-phi. MLCHC Annual Clinical Conference Worcester, MA Wednesday, November 12, 2014 2:15pm 3:30pm

Data Security and Integrity of e-phi. MLCHC Annual Clinical Conference Worcester, MA Wednesday, November 12, 2014 2:15pm 3:30pm Electronic Health Records: Data Security and Integrity of e-phi Worcester, MA Wednesday, 2:15pm 3:30pm Agenda Introduction Learning Objectives Overview of HIPAA HIPAA: Privacy and Security HIPAA: The Security

More information

Welcome to the Privacy and Security PowerPoint presentation in the Data Analytics Toolkit. This presentation will provide introductory information

Welcome to the Privacy and Security PowerPoint presentation in the Data Analytics Toolkit. This presentation will provide introductory information Welcome to the Privacy and Security PowerPoint presentation in the Data Analytics Toolkit. This presentation will provide introductory information about HIPAA, the HITECH-HIPAA Omnibus Privacy Act, how

More information

HIPAA 101. March 18, 2015 Webinar

HIPAA 101. March 18, 2015 Webinar HIPAA 101 March 18, 2015 Webinar Agenda Acronyms to Know HIPAA Basics What is HIPAA and to whom does it apply? What is protected by HIPAA? Privacy Rule Security Rule HITECH Basics Breaches and Responses

More information

HIPAA in an Omnibus World. Presented by

HIPAA in an Omnibus World. Presented by HIPAA in an Omnibus World Presented by HITECH COMPLIANCE ASSOCIATES IS NOT A LAW FIRM The information given is not intended to be a substitute for legal advice or consultation. As always in legal matters

More information

12/19/2014. HIPAA More Important Than You Realize. Administrative Simplification Privacy Rule Security Rule

12/19/2014. HIPAA More Important Than You Realize. Administrative Simplification Privacy Rule Security Rule HIPAA More Important Than You Realize J. Ira Bedenbaugh Consulting Shareholder February 20, 2015 This material was used by Elliott Davis Decosimo during an oral presentation; it is not a complete record

More information

Heather L. Hughes, J.D. HIPAA Privacy Officer U.S. Legal Support, Inc. hhughes@uslegalsupport.com www.uslegalsupport.com

Heather L. Hughes, J.D. HIPAA Privacy Officer U.S. Legal Support, Inc. hhughes@uslegalsupport.com www.uslegalsupport.com Heather L. Hughes, J.D. HIPAA Privacy Officer U.S. Legal Support, Inc. hhughes@uslegalsupport.com www.uslegalsupport.com HIPAA Privacy Rule Sets standards for confidentiality and privacy of individually

More information

How to Use the NYeC Privacy and Security Toolkit V 1.1

How to Use the NYeC Privacy and Security Toolkit V 1.1 How to Use the NYeC Privacy and Security Toolkit V 1.1 Scope of the Privacy and Security Toolkit The tools included in the Privacy and Security Toolkit serve as guidance for educating stakeholders about

More information

Business Associate Management Methodology

Business Associate Management Methodology Methodology auxilioinc.com 844.874.0684 Table of Contents Methodology Overview 3 Use Case 1: Upstream of s I manage business associates 4 System 5 Use Case 2: Eco System of s I manage business associates

More information

Hosting for Healthcare: ADDRESSING THE UNIQUE ISSUES OF HEALTH IT & ACHIEVING END-TO-END COMPLIANCE

Hosting for Healthcare: ADDRESSING THE UNIQUE ISSUES OF HEALTH IT & ACHIEVING END-TO-END COMPLIANCE Hosting for Healthcare: ADDRESSING THE UNIQUE ISSUES OF HEALTH IT & ACHIEVING END-TO-END COMPLIANCE [ Hosting for Healthcare: Addressing the Unique Issues of Health IT & Achieving End-to-End Compliance

More information

HIPAA Omnibus Rule Overview. Presented by: Crystal Stanton MicroMD Marketing Communication Specialist

HIPAA Omnibus Rule Overview. Presented by: Crystal Stanton MicroMD Marketing Communication Specialist HIPAA Omnibus Rule Overview Presented by: Crystal Stanton MicroMD Marketing Communication Specialist 1 HIPAA Omnibus Rule - Agenda History of the Omnibus Rule What is the HIPAA Omnibus Rule and its various

More information

Welcome to ChiroCare s Fourth Annual Fall Business Summit. October 3, 2013

Welcome to ChiroCare s Fourth Annual Fall Business Summit. October 3, 2013 Welcome to ChiroCare s Fourth Annual Fall Business Summit October 3, 2013 HIPAA Compliance Regulatory Overview & Implementation Tips for Providers Agenda Green packet Overview of general HIPAA terms and

More information

HIPAA and Mental Health Privacy:

HIPAA and Mental Health Privacy: HIPAA and Mental Health Privacy: What Social Workers Need to Know Presenter: Sherri Morgan, JD, MSW Associate Counsel, NASW Legal Defense Fund and Office of Ethics & Professional Review 2010 National Association

More information

HIPAA Compliance: Are you prepared for the new regulatory changes?

HIPAA Compliance: Are you prepared for the new regulatory changes? HIPAA Compliance: Are you prepared for the new regulatory changes? Baker Tilly CARIS Innovation, Inc. April 30, 2013 Baker Tilly refers to Baker Tilly Virchow Krause, LLP, an independently owned and managed

More information

Health Care Information Privacy The HIPAA Regulations What Has Changed and What You Need to Know

Health Care Information Privacy The HIPAA Regulations What Has Changed and What You Need to Know Health Care Information Privacy The HIPAA Regulations What Has Changed and What You Need to Know Note: Information provided to NCRA by Melodi Gates, Associate with Patton Boggs, LLC Privacy and data protection

More information

Business Associates, HITECH & the Omnibus HIPAA Final Rule

Business Associates, HITECH & the Omnibus HIPAA Final Rule Business Associates, HITECH & the Omnibus HIPAA Final Rule HIPAA Omnibus Final Rule Changes Business Associates Marissa Gordon-Nguyen, JD, MPH Health Information Privacy Specialist Office for Civil Rights/HHS

More information

Meaningful Use and Security Risk Analysis

Meaningful Use and Security Risk Analysis Meaningful Use and Security Risk Analysis Meeting the Measure Security in Transition Executive Summary Is your organization adopting Meaningful Use, either to gain incentive payouts or to avoid penalties?

More information

HIPAA/HITECH Privacy and Security for Long Term Care. Association of Jewish Aging Services 1

HIPAA/HITECH Privacy and Security for Long Term Care. Association of Jewish Aging Services 1 HIPAA/HITECH Privacy and Security for Long Term Care 1 John DiMaggio Chief Executive Officer, Blue Orange Compliance Cliff Mull Partner, Benesch, Healthcare Practice Group About the Presenters John DiMaggio,

More information

Art Gross President & CEO HIPAA Secure Now! How to Prepare for the 2015 HIPAA Audits and Avoid Data Breaches

Art Gross President & CEO HIPAA Secure Now! How to Prepare for the 2015 HIPAA Audits and Avoid Data Breaches Art Gross President & CEO HIPAA Secure Now! How to Prepare for the 2015 HIPAA Audits and Avoid Data Breaches Speakers Phillip Long CEO at Business Information Solutions Art Gross President & CEO of HIPAA

More information

The HIPAA Audit Program

The HIPAA Audit Program The HIPAA Audit Program Anna C. Watterson Davis Wright Tremaine LLP The U.S. Department of Health and Human Services (HHS) was given authority, and a mandate, to conduct periodic audits of HIPAA 1 compliance

More information

Isaac Willett April 5, 2011

Isaac Willett April 5, 2011 Current Options for EHR Implementation: Cloud or No Cloud? Regina Sharrow Isaac Willett April 5, 2011 Introduction Health Information Technology for Economic and Clinical Health Act ( HITECH (HITECH Act

More information

HIPAA and HITECH Compliance for Cloud Applications

HIPAA and HITECH Compliance for Cloud Applications What Is HIPAA? The healthcare industry is rapidly moving towards increasing use of electronic information systems - including public and private cloud services - to provide electronic protected health

More information

OCRA Spring Convention ~ 2014 Phyllis Craver Lykken, RPR, CLR, CCR 2463. Court Reporters and HIPAA

OCRA Spring Convention ~ 2014 Phyllis Craver Lykken, RPR, CLR, CCR 2463. Court Reporters and HIPAA Court Reporters and HIPAA OCRA Spring Convention ~ 2014 Phyllis Craver Lykken, RPR, CLR, CCR 2463 1 What Exactly is HIPAA? HIPAA is an acronym for the Health Insurance Portability and Accountability Act

More information

Am I a Business Associate? Do I want to be a Business Associate? What are my obligations?

Am I a Business Associate? Do I want to be a Business Associate? What are my obligations? Am I a Business Associate? Do I want to be a Business Associate? What are my obligations? Brought to you by Winston & Strawn s Health Care Practice Group 2013 Winston & Strawn LLP Today s elunch Presenters

More information

Our Commitment to Information Security

Our Commitment to Information Security Our Commitment to Information Security What is HIPPA? Health Insurance Portability and Accountability Act 1996 The HIPAA Privacy regulations require health care providers and organizations, as well as

More information

Decrypting the Security Risk Assessment (SRA) Requirement for Meaningful Use

Decrypting the Security Risk Assessment (SRA) Requirement for Meaningful Use Click to edit Master title style Decrypting the Security Risk Assessment (SRA) Requirement for Meaningful Use Andy Petrovich, MHSA, MPH M-CEITA / Altarum Institute April 8, 2015 4/8/2015 1 1 Who is M-CEITA?

More information

NCHICA HITECH Act Breach Notification Risk Assessment Tool. Prepared by the NCHICA Privacy, Security & Legal Officials Workgroup

NCHICA HITECH Act Breach Notification Risk Assessment Tool. Prepared by the NCHICA Privacy, Security & Legal Officials Workgroup NCHICA HITECH Act Breach Notification Risk Assessment Tool Prepared by the NCHICA Privacy, Security & Legal Officials Workgroup NORTH CAROLINA HEALTHCARE INFORMATION AND COMMUNICATIONS ALLIANCE, INC August

More information

Sunday March 30, 2014, 9am noon HCCA Conference, San Diego

Sunday March 30, 2014, 9am noon HCCA Conference, San Diego Meaningful Use as it Relates to HIPAA Compliance Sunday March 30, 2014, 9am noon HCCA Conference, San Diego CLAconnect.com Objectives and Agenda Understand the statutory and regulatory background and purpose

More information

Arizona State University. HIPAA Compliance. Audit Report Number 15-08. May 7, 2015

Arizona State University. HIPAA Compliance. Audit Report Number 15-08. May 7, 2015 This page left blank intentionally. Summary The Health Insurance Portability and Accountability Act of 1996 (HIPAA) audit was included on the Arizona State University (ASU) FY 2015 annual audit plan approved

More information

OCR UPDATE Breach Notification Rule & Business Associates (BA)

OCR UPDATE Breach Notification Rule & Business Associates (BA) OCR UPDATE Breach Notification Rule & Business Associates (BA) Alicia Galan Supervisory Equal Opportunity Specialist March 7, 2014 HITECH OMNIBUS A Reminder of What s Included: Final Modifications of the

More information

HHS Finalizes HIPAA Privacy and Data Security Rules, Including Stricter Rules for Breaches of Unsecured PHI

HHS Finalizes HIPAA Privacy and Data Security Rules, Including Stricter Rules for Breaches of Unsecured PHI January 23, 2013 HHS Finalizes HIPAA Privacy and Data Security Rules, Including Stricter Rules for Breaches of Unsecured PHI Executive Summary HHS has issued final regulations that address recent legislative

More information

New HIPAA regulations require action. Are you in compliance?

New HIPAA regulations require action. Are you in compliance? New HIPAA regulations require action. Are you in compliance? Mary Harrison, JD Tami Simon, JD May 22, 2013 Discussion topics Introduction Remembering the HIPAA Basics HIPAA Privacy Rules HIPAA Security

More information

Bridging the HIPAA/HITECH Compliance Gap

Bridging the HIPAA/HITECH Compliance Gap CyberSheath Healthcare Compliance Paper www.cybersheath.com -65 Bridging the HIPAA/HITECH Compliance Gap Security insights that help covered entities and business associates achieve compliance According

More information

University Healthcare Physicians Compliance and Privacy Policy

University Healthcare Physicians Compliance and Privacy Policy Page 1 of 11 POLICY University Healthcare Physicians (UHP) will enter into business associate agreements in compliance with the provisions of the Health Insurance Portability and Accountability Act of

More information

The HIPAA Omnibus Final Rule

The HIPAA Omnibus Final Rule WHITE PAPER The HIPAA Omnibus Final Rule Four risk exposure events that can uncover compliance issues leading to investigations, potential fines, and damage to your organization s reputation. By Virginia

More information

HIPAA Enforcement is Here

HIPAA Enforcement is Here HIPAA Enforcement is Here Risks and rewards for MSPs Cam Roberson Director, Reseller Channel Beachhead Solutions THIS JUST IN History of HIPAA Security 1996 Congress Passes Health Insurance Portability

More information

HIPAA Security Rule Compliance

HIPAA Security Rule Compliance HIPAA Security Rule Compliance Caryn Reiker MAXIS360 HIPAA Security Rule Compliance what is it and why you should be concerned about it Table of Contents About HIPAA... 2 Who Must Comply... 2 The HIPAA

More information

Please Read. Apgar & Associates, LLC apgarandassoc.com P. O. Box 80278 Portland, OR 97280 503-384-2538 877-376-1981 503-384-2539 Fax

Please Read. Apgar & Associates, LLC apgarandassoc.com P. O. Box 80278 Portland, OR 97280 503-384-2538 877-376-1981 503-384-2539 Fax Please Read This business associate audit questionnaire is part of Apgar & Associates, LLC s healthcare compliance resources, Copyright 2014. This questionnaire should be viewed as a tool to aid in evaluating

More information

2011 2012 Aug. Sept. Oct. Nov. Dec. Jan. Feb. March April May-Dec.

2011 2012 Aug. Sept. Oct. Nov. Dec. Jan. Feb. March April May-Dec. The OCR Auditors are coming - Are you next? What to Expect and How to Prepare On June 10, 2011, the U.S. Department of Health and Human Services Office for Civil Rights ( OCR ) awarded KPMG a $9.2 million

More information

Lessons Learned from Recent HIPAA and Big Data Breaches. Briar Andresen Katie Ilten Ann Ladd

Lessons Learned from Recent HIPAA and Big Data Breaches. Briar Andresen Katie Ilten Ann Ladd Lessons Learned from Recent HIPAA and Big Data Breaches Briar Andresen Katie Ilten Ann Ladd Recent health care breaches Breach reports to OCR as of February 2015 1,144 breaches involving 500 or more individual

More information

HIPAA Changes 2013. Mike Jennings & Jonathan Krasner BEI For MCMS 07/23/13

HIPAA Changes 2013. Mike Jennings & Jonathan Krasner BEI For MCMS 07/23/13 HIPAA Changes 2013 Mike Jennings & Jonathan Krasner BEI For MCMS 07/23/13 BEI Who We Are DC Metro IT Service Provider since 1987 Network Design/Upgrade Installation/Managed IT Services for small to medium-sized

More information

THE HIPAA TANGO CHOREOGRAPHING PRIVACY AND SECURITY UNDER THE FINAL RULE

THE HIPAA TANGO CHOREOGRAPHING PRIVACY AND SECURITY UNDER THE FINAL RULE THE HIPAA TANGO CHOREOGRAPHING PRIVACY AND SECURITY UNDER THE FINAL RULE The Speakers Cinda Velasco Attorney, Manager, Privacy Officer Patient Safety and Risk Management Trish Lugtu Senior Manager MMIC

More information

Vendor Management Challenges and Solutions for HIPAA Compliance. Jim Sandford Vice President, Coalfire

Vendor Management Challenges and Solutions for HIPAA Compliance. Jim Sandford Vice President, Coalfire Vendor Management Challenges and Solutions for HIPAA Compliance Jim Sandford Vice President, Coalfire Housekeeping You may submit questions throughout the webinar using the question area in the control

More information

HIPAA Audits: How to Be Prepared. Lindsey Wiley, MHA, CHTS-IM, CHTS-TS HIT Manager Oklahoma Foundation for Medical Quality

HIPAA Audits: How to Be Prepared. Lindsey Wiley, MHA, CHTS-IM, CHTS-TS HIT Manager Oklahoma Foundation for Medical Quality HIPAA Audits: How to Be Prepared Lindsey Wiley, MHA, CHTS-IM, CHTS-TS HIT Manager Oklahoma Foundation for Medical Quality An Important Reminder For audio, you must use your phone: Step 1: Call (866) 906-0123.

More information

Healthcare and IT Working Together. 2013 KY HFMA Spring Institute

Healthcare and IT Working Together. 2013 KY HFMA Spring Institute Healthcare and IT Working Together 2013 KY HFMA Spring Institute Introduction Michael R Gilliam Over 7 Years Experience in Cyber Security BA Telecommunications Network Security CISSP, GHIC, CCFE, SnortCP,

More information

HIPAA Omnibus Rule Practice Impact. Kristen Heffernan MicroMD Director of Prod Mgt and Marketing

HIPAA Omnibus Rule Practice Impact. Kristen Heffernan MicroMD Director of Prod Mgt and Marketing HIPAA Omnibus Rule Practice Impact Kristen Heffernan MicroMD Director of Prod Mgt and Marketing 1 HIPAA Omnibus Rule Agenda History of the Rule HIPAA Stats Rule Overview Use of Personal Health Information

More information

My Docs Online HIPAA Compliance

My Docs Online HIPAA Compliance My Docs Online HIPAA Compliance Updated 10/02/2013 Using My Docs Online in a HIPAA compliant fashion depends on following proper usage guidelines, which can vary based on a particular use, but have several

More information

M E M O R A N D U M. Definitions

M E M O R A N D U M. Definitions M E M O R A N D U M DATE: November 10, 2011 TO: FROM: RE: Krevolin & Horst, LLC HIPAA Obligations of Business Associates In connection with the launch of your hosted application service focused on practice

More information

9/14/2015. Before we begin. Learning Objectives. Kevin Secrest IT Audit Manager, University of Pennsylvania

9/14/2015. Before we begin. Learning Objectives. Kevin Secrest IT Audit Manager, University of Pennsylvania Evaluating and Managing Third Party IT Service Providers Are You Really Getting The Assurance You Need To Mitigate Information Security and Privacy Risks? Kevin Secrest IT Audit Manager, University of

More information

Developing HIPAA Security Compliance. Trish Lugtu CPHIMS, CHP, CHSS Health IT Consultant

Developing HIPAA Security Compliance. Trish Lugtu CPHIMS, CHP, CHSS Health IT Consultant Developing HIPAA Security Compliance Trish Lugtu CPHIMS, CHP, CHSS Health IT Consultant Learning Objectives Identify elements of a HIPAA Security compliance program Learn the HIPAA Security Rule basics

More information

Nationwide Review of CMS s HIPAA Oversight. Brian C. Johnson, CPA, CISA. Wednesday, January 19, 2011

Nationwide Review of CMS s HIPAA Oversight. Brian C. Johnson, CPA, CISA. Wednesday, January 19, 2011 Nationwide Review of CMS s HIPAA Oversight Brian C. Johnson, CPA, CISA Wednesday, January 19, 2011 1 WHAT I DO Manage Region IV IT Audit and Advance Audit Technique Staff (AATS) IT Audit consists of 8

More information

Aligning Your Research Cyberinfrastructure with HIPAA and FISMA

Aligning Your Research Cyberinfrastructure with HIPAA and FISMA Aligning Your Research Cyberinfrastructure with HIPAA and FISMA Anurag Shankar Center for Applied Cybersecurity Research Indiana University 2015 NSF Cybersecurity Summit for Large Facilities and Cyberinfrastructure

More information

FIVE EASY STEPS FOR HANDLING NEW HIPAA REQUIREMENTS & MANAGING YOUR ELECTRONIC COMMUNICATIONS

FIVE EASY STEPS FOR HANDLING NEW HIPAA REQUIREMENTS & MANAGING YOUR ELECTRONIC COMMUNICATIONS FIVE EASY STEPS FOR HANDLING NEW HIPAA REQUIREMENTS & MANAGING YOUR ELECTRONIC COMMUNICATIONS James J. Eischen, Jr., Esq. October 2013 Chicago, Illinois JAMES J. EISCHEN, JR., ESQ. Partner at Higgs, Fletcher

More information

HIPAA and the HITECH Act Privacy and Security of Health Information in 2009

HIPAA and the HITECH Act Privacy and Security of Health Information in 2009 HIPAA and the HITECH Act Privacy and Security of Health Information in 2009 What is HIPAA? Health Insurance Portability & Accountability Act of 1996 Effective April 13, 2003 Federal Law HIPAA Purpose:

More information

It s a New Regulatory Landscape: Do You Know Where Your Business Associates are and What They are Doing?

It s a New Regulatory Landscape: Do You Know Where Your Business Associates are and What They are Doing? It s a New Regulatory Landscape: Do You Know Where Your Business Associates are and What They are Doing? The AMC Privacy & Security Conference Series Securely Connecting Communities for Improved Health

More information

Implications of HIPAA Requirements on Healthcare Payment Processing

Implications of HIPAA Requirements on Healthcare Payment Processing Implications of HIPAA Requirements on Healthcare Payment Processing Linda M Wolverton Vice President, Compliance, TEAMHealth Lynne Pearson Vice President, National Healthcare Treasury Management Fifth

More information

Trust 9/10/2015. Why Does Privacy and Security Matter? Who Must Comply with HIPAA Rules? HIPAA Breaches, Security Risk Analysis, and Audits

Trust 9/10/2015. Why Does Privacy and Security Matter? Who Must Comply with HIPAA Rules? HIPAA Breaches, Security Risk Analysis, and Audits HIPAA Breaches, Security Risk Analysis, and Audits Derrick Hill Senior Health IT Advisor Kentucky REC Why Does Privacy and Security Matter? Trust Who Must Comply with HIPAA Rules? Covered Entities (CE)

More information

INFORMATION SECURITY & HIPAA COMPLIANCE MPCA

INFORMATION SECURITY & HIPAA COMPLIANCE MPCA INFORMATION SECURITY & HIPAA COMPLIANCE MPCA Annual Conference August 5, 201 Agenda 1 HIPAA 2 The New Healthcare Paradigm Internal Compliance 4 Conclusion 2 1 HIPAA 1 Earning Their Trust 4 HIPAA 5 Health

More information

Am I a Business Associate?

Am I a Business Associate? Am I a Business Associate? Now What? JENNIFER L. RATHBURN Quarles & Brady LLP KATEA M. RAVEGA Quarles & Brady LLP agenda» Overview of HIPAA / HITECH» Business Associate ( BA ) Basics» What Do BAs Have

More information

OCR s Anatomy: HIPAA Breaches, Investigations, and Enforcement

OCR s Anatomy: HIPAA Breaches, Investigations, and Enforcement OCR s Anatomy: HIPAA Breaches, Investigations, and Enforcement Clinton Mikel The Health Law Partners, P.C. Alessandra Swanson U.S. Department of Health and Human Services - Office for Civil Rights Disclosure

More information

OCR Reports on the Enforcement. Learning Objectives 4/1/2013. HIPAA Compliance/Enforcement (As of December 31, 2012) HCCA Compliance Institute

OCR Reports on the Enforcement. Learning Objectives 4/1/2013. HIPAA Compliance/Enforcement (As of December 31, 2012) HCCA Compliance Institute OCR Reports on the Enforcement of the HIPAA Rules HCCA Compliance Institute April 22, 2013 David Holtzman Sr. Health IT & Privacy Specialist U.S. Department of Health and Human Services Office for Civil

More information

OCR Reports on the Enforcement. Learning Objectives

OCR Reports on the Enforcement. Learning Objectives OCR Reports on the Enforcement of the HIPAA Rules HCCA Compliance Institute April 22, 2013 David Holtzman Sr. Health IT & Privacy Specialist U.S. Department of Health and Human Services Office for Civil

More information

AHLA. B. HIPAA Compliance Audits. Marti Arvin Chief Compliance Officer UCLA Health System and David Geffen School of Medicine Los Angeles, CA

AHLA. B. HIPAA Compliance Audits. Marti Arvin Chief Compliance Officer UCLA Health System and David Geffen School of Medicine Los Angeles, CA AHLA B. HIPAA Compliance Audits Marti Arvin Chief Compliance Officer UCLA Health System and David Geffen School of Medicine Los Angeles, CA Anna C. Watterson Davis Wright Tremaine LLP Washington, DC Fraud

More information

OCR HIPAA Audit Readiness. ISACA - North Texas Chapter April 11, 2013

OCR HIPAA Audit Readiness. ISACA - North Texas Chapter April 11, 2013 ISACA - North Texas Chapter April 11, 2013 Introduction 1 2 Basic components of HIPAA and HITECH legislation HITECH and rising breaches 3 4 OCR HIPAA audits Key findings of the pilot audits 5 Approaches

More information

Creating Stable Security & Compliance Relationships

Creating Stable Security & Compliance Relationships Creating Stable Security & Compliance Relationships David Holtzman JD, CIPP/G VP, Compliance CynergisTek, Inc. James Wieland JD Principal Ober Kaler Welcome The slides for today s webinar are available

More information

What do you need to know?

What do you need to know? What do you need to know? DISCLAIMER Please note that the information provided is to inform our clients and friends of recent HIPAA and HITECH act developments. It is not intended, nor should it be used,

More information

HIPAA Compliance Review Analysis and Summary of Results

HIPAA Compliance Review Analysis and Summary of Results HIPAA Compliance Review Analysis and Summary of Results Centers for Medicare & Medicaid Services (CMS) Office of E-Health Standards and Services (OESS) Reviews 2008 Table of Contents Introduction 1 Risk

More information

Guidance on Risk Analysis Requirements under the HIPAA Security Rule

Guidance on Risk Analysis Requirements under the HIPAA Security Rule Guidance on Risk Analysis Requirements under the HIPAA Security Rule Introduction The Office for Civil Rights (OCR) is responsible for issuing annual guidance on the provisions in the HIPAA Security Rule.

More information

COMPLIANCE ALERT 10-12

COMPLIANCE ALERT 10-12 HAWAII HEALTH SYSTEMS C O R P O R A T I O N "Touching Lives Every Day COMPLIANCE ALERT 10-12 HIPAA Expansion under the American Recovery and Reinvestment Act of 2009 The American Recovery and Reinvestment

More information

HIPAA Privacy & Breach Notification Training for System Administration Business Associates

HIPAA Privacy & Breach Notification Training for System Administration Business Associates HIPAA Privacy & Breach Notification Training for System Administration Business Associates Barbara M. Holthaus privacyofficer@utsystem.edu Office of General Counsel University of Texas System April 10,

More information

Information Security Handbook

Information Security Handbook Information Security Handbook Adopted 6/4/14 Page 0 Page 1 1. Introduction... 5 1.1. Executive Summary... 5 1.2. Governance... 5 1.3. Scope and Application... 5 1.4. Biennial Review... 5 2. Definitions...

More information

Are You Still HIPAA Compliant? Staying Protected in the Wake of the Omnibus Final Rule Click to edit Master title style.

Are You Still HIPAA Compliant? Staying Protected in the Wake of the Omnibus Final Rule Click to edit Master title style. Are You Still HIPAA Compliant? Staying Protected in the Wake of the Omnibus Final Rule Click to edit Master title style March 27, 2013 www.mcguirewoods.com Introductions Holly Carnell McGuireWoods LLP

More information

A How-To Guide for Updating HIPAA Policies & Procedures to Align with ARRA Health Care Provider Edition Version 1

A How-To Guide for Updating HIPAA Policies & Procedures to Align with ARRA Health Care Provider Edition Version 1 A How-To Guide for Updating HIPAA Policies & Procedures to Align with ARRA Health Care Provider Edition Version 1 Policy and Procedure Templates Reflects modifications published in the Federal Register

More information

What is required of a compliant Risk Assessment?

What is required of a compliant Risk Assessment? What is required of a compliant Risk Assessment? ACR 2 Solutions President Jack Kolk discusses the nine elements that the Office of Civil Rights requires Covered Entities perform when conducting a HIPAA

More information

Privacy Officer Job Description 4/28/2014. HIPAA Privacy Officer Orientation. Cathy Montgomery, RN. Presented by:

Privacy Officer Job Description 4/28/2014. HIPAA Privacy Officer Orientation. Cathy Montgomery, RN. Presented by: HIPAA Privacy Officer Orientation Presented by: Cathy Montgomery, RN Privacy Officer Job Description Serve as leader Develop Policies and Procedures Train staff Monitor activities Manage Business Associates

More information

HIPAA Security Risk Analysis for Meaningful Use

HIPAA Security Risk Analysis for Meaningful Use HIPAA Security Risk Analysis for Meaningful Use NOTE: Make sure your computer speakers are turned ON. Audio will be streaming through your speakers. If you do not have computer speakers, call the ACCMA

More information

Building Trust and Confidence in Healthcare Information. How TrustNet Helps

Building Trust and Confidence in Healthcare Information. How TrustNet Helps Building Trust and Confidence in Healthcare Information The management of healthcare information in the United States is regulated under the HIPAA (Health Insurance Portability and Accountability Act)

More information

HHS Issues New HITECH/HIPAA Rule: Implications for Hospice Providers

HHS Issues New HITECH/HIPAA Rule: Implications for Hospice Providers Compliance Tip Sheet National Hospice and Palliative Care Organization www.nhpco.org/regulatory HHS Issues New HITECH/HIPAA Rule: Implications for Hospice Providers Hospice Provider Compliance To Do List

More information

HIPAA Compliance The Time is Now Changes on the Horizon: The Final Regulations on Privacy and Security. May 7, 2013

HIPAA Compliance The Time is Now Changes on the Horizon: The Final Regulations on Privacy and Security. May 7, 2013 HIPAA Compliance The Time is Now Changes on the Horizon: The Final Regulations on Privacy and Security May 7, 2013 Presenters James Clay President Employee Benefits & HR Consulting The Miller Group jimc@millercares.com

More information

THE STATE OF HEALTHCARE COMPLIANCE: Keeping up with HIPAA, Advancements in EHR & Additional Regulations

THE STATE OF HEALTHCARE COMPLIANCE: Keeping up with HIPAA, Advancements in EHR & Additional Regulations THE STATE OF HEALTHCARE COMPLIANCE: Keeping up with HIPAA, Advancements in EHR & Additional Regulations [ The State of Healthcare Compliance: Keeping up with HIPAA, Advancements in EHR & Additional Regulations

More information

BUSINESS ASSOCIATE AGREEMENT. Recitals

BUSINESS ASSOCIATE AGREEMENT. Recitals BUSINESS ASSOCIATE AGREEMENT This Agreement is executed this 8 th day of February, 2013, by BETA Healthcare Group. Recitals BETA Healthcare Group consists of BETA Risk Management Authority (BETARMA) and

More information

HIPAA COMPLIANCE AND DATA PROTECTION. sales@eaglenetworks.it +39 030 201.08.25 Page 1

HIPAA COMPLIANCE AND DATA PROTECTION. sales@eaglenetworks.it +39 030 201.08.25 Page 1 HIPAA COMPLIANCE AND DATA PROTECTION sales@eaglenetworks.it +39 030 201.08.25 Page 1 CONTENTS Introduction..... 3 The HIPAA Security Rule... 4 The HIPAA Omnibus Rule... 6 HIPAA Compliance and EagleHeaps

More information

STATE OF NEVADA DEPARTMENT OF HEALTH AND HUMAN SERVICES BUSINESS ASSOCIATE ADDENDUM

STATE OF NEVADA DEPARTMENT OF HEALTH AND HUMAN SERVICES BUSINESS ASSOCIATE ADDENDUM STATE OF NEVADA DEPARTMENT OF HEALTH AND HUMAN SERVICES BUSINESS ASSOCIATE ADDENDUM BETWEEN The Division of Health Care Financing and Policy Herein after referred to as the Covered Entity and (Enter Business

More information

Nine Network Considerations in the New HIPAA Landscape

Nine Network Considerations in the New HIPAA Landscape Guide Nine Network Considerations in the New HIPAA Landscape The Health Insurance Portability and Accountability Act of 1996 (HIPAA) Omnibus Final Rule, released January 2013, introduced some significant

More information

The Case For HIPAA Risk Assessment. Leader s Guide

The Case For HIPAA Risk Assessment. Leader s Guide 4547 The Case For HIPAA Risk Assessment Leader s Guide IMPORTANT INFORMATION FOR EDUCATION COORDINATORS & PROGRAM FACILITATORS PLEASE NOTE: In order for this program to meet Florida course requirements,

More information

Understanding HIPAA Regulations and How They Impact Your Organization!

Understanding HIPAA Regulations and How They Impact Your Organization! Understanding HIPAA Regulations and How They Impact Your Organization! Presented by: HealthInfoNet & Systems Engineering! April 25 th 2013! Introductions! Todd Rogow Director of IT HealthInfoNet Adam Victor

More information

Data Breach, Electronic Health Records and Healthcare Reform

Data Breach, Electronic Health Records and Healthcare Reform Data Breach, Electronic Health Records and Healthcare Reform (This presentation is for informational purposes only and it is not intended, and should not be relied upon, as legal advice.) Overview of HIPAA

More information

HIPAA OMNIBUS RULE: EXPANDED COMPLIANCE REQUIREMENTS

HIPAA OMNIBUS RULE: EXPANDED COMPLIANCE REQUIREMENTS HIPAA OMNIBUS RULE: EXPANDED COMPLIANCE REQUIREMENTS James J. Eischen, Jr., Esq. November 2013 San Diego, California JAMES J. EISCHEN, JR., ESQ. Partner at Higgs, Fletcher & Mack, LLP 26+ years of experience

More information

The ReHabilitation Center. 1439 Buffalo Street. Olean. NY. 14760

The ReHabilitation Center. 1439 Buffalo Street. Olean. NY. 14760 Procedure Name: HITECH Breach Notification The ReHabilitation Center 1439 Buffalo Street. Olean. NY. 14760 Purpose To amend The ReHabilitation Center s HIPAA Policy and Procedure to include mandatory breach

More information

THE BEST PRACTICES FOR DATA SECURITY AND PRIVACY IN VENDOR/ CLIENT RELATIONSHIPS

THE BEST PRACTICES FOR DATA SECURITY AND PRIVACY IN VENDOR/ CLIENT RELATIONSHIPS THE BEST PRACTICES FOR DATA SECURITY AND PRIVACY IN VENDOR/ CLIENT RELATIONSHIPS Data Law Group, P.C. Kari Kelly Deborah Shinbein YOU CAN T OUTSOURCE COMPLIANCE! Various statutes and regulations govern

More information

Top Ten Technology Risks Facing Colleges and Universities

Top Ten Technology Risks Facing Colleges and Universities Top Ten Technology Risks Facing Colleges and Universities Chris Watson, MBA, CISA, CRISC Manager, Internal Audit and Risk Advisory Services cwatson@schneiderdowns.com April 23, 2012 Overview Technology

More information