New HIPAA regulations require action. Are you in compliance?

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "New HIPAA regulations require action. Are you in compliance?"

Transcription

1 New HIPAA regulations require action. Are you in compliance? Mary Harrison, JD Tami Simon, JD May 22, 2013

2 Discussion topics Introduction Remembering the HIPAA Basics HIPAA Privacy Rules HIPAA Security Rules Final omnibus regulations Enforcement update Employer action items Questions 2

3 History of HIPAA HIPAA privacy and security rules were first announced in Since then, several rounds of regulations and guidance addressed the safeguards required for an individual s protected health information (PHI). The Health Information Technology for Economic and Clinical Health (HITECH) Act The Genetic Information Nondiscrimination Act of 2008 (GINA) Accounting of disclosure regulations The omnibus regulations pull together several of these past regulations Compliance effective date: Sept. 23, 2013 Accounting of disclosures and an individual s right to receive an access report guidance still forthcoming 3

4 Remembering the HIPAA Basics

5 What kind of personal information does HIPAA protect? Protected Health Information (PHI) is: Individually identifiable health information, including demographic information collected from an individual, that: is created or received by a healthcare provider, health plan, employer, or healthcare data clearing house; and relates to the past, present or future physical or mental health or condition of an individual, the provision of healthcare to an individual, or the past, present, or future payments for the provision of healthcare to an individual e-phi is PHI in electronic media, whether: At rest in a storage device o For example, computer hard drive, disk, CD, and flash drive/memory stick; OR In transit via internet, dial-up lines, etc. o For example, , File Transfer Protocol (FTP), electronic data interchange (EDI), interactive voice response (IVR), and fax back systems that transmit PHI What form can it take? Print; Electronic (including ); Oral 5

6 Individually identifiable If an individual can be identified using the information alone or in combination, then it is individually identifiable. Examples include the following: Consider the circumstances as well. For example, in a report by department and age, if only one in the group is over 60, that person can be identified. 6

7 HIPAA quiz 7

8 Who does HIPAA apply to? Privacy and security rules apply directly to Covered Entities Group health plans Providers who perform certain standard transactions electronically Health care data clearinghouses Business Associates with access to protected health care information* Employers are not Covered Entities; but as the plan sponsors, they must ensure their plans comply with HIPAA * Expanded under omnibus regulations 8

9 What is a group health plan? Medical Dental Vision Health Flexible Spending Account Prescription drugs Some employee assistance programs Note: Rules apply to both insured and self-funded arrangements 9

10 Types of common group health plan PHI and e-phi 10

11 The HIPAA Privacy Rules

12 Overview - Privacy Privacy Standards require that PHI be safeguarded, but primarily address: Who can have access to PHI How PHI can be used and disclosed A Covered Entity is not permitted to release or use PHI except for: Specific administrative functions Treatment Payment (e.g., eligibility or coverage determinations, claim resolution) Health plan operations (e.g., underwriting, contract renewal) Disclosures that the individual authorizes in writing Disclosures to the individual in accordance with their rights under HIPAA Disclosures made for legal or public policy reasons Creates individual rights No pre-emption of other state or federal laws that are more restrictive 12

13 Minimum necessary standard May disclose only minimum PHI necessary to achieve the purpose of the use or disclosure Routine disclosures: Must establish policies and procedures to limit disclosure of PHI; case-by-case review unnecessary Non-routine disclosures: Must have criteria for evaluating specific situation must be approved by the Privacy Officer Does not apply to: Disclosures made in accordance with authorization Disclosures made to the individual Disclosures required by law Disclosures for the treatment of the individual 13

14 Individual rights The privacy rules provide individuals (employees, retirees and dependents) with specific rights Right to notice of privacy rights, policies and procedures Right to access and/or amend their own PHI in designated record set Right to authorize non-exempt uses and disclosures Right to an accounting of non-exempt disclosures of PHI over past 6 years upon request Right to communications made by an alternative means or at alternative location when requested Right to access electronic information (changed in omnibus regulation) Right to restrict certain disclosures (changed in omnibus regulation) 14

15 The HIPAA Security Rules

16 HIPAA security rule Covered Entities must: Ensure the confidentiality, integrity and availability of all e-phi the Covered Entity creates, receives, maintains or transmits o o o Confidentiality the information will not be disclosed to unauthorized individuals or processes Integrity the condition of data or information will not be altered or destroyed in an unauthorized manner. Data from one system is consistently and accurately transferred to other systems Availability the data or information is accessible and useable upon demand by an authorized person Protect against any reasonably anticipated threats or hazards to the security or integrity of such information Ensure compliance with rules 16

17 Security standards Security Standards are Multidimensional Administrative Physical Safeguards Technical Security Mechanisms/Services Security Management Security Responsibility Workforce Security Information Access Management Security Awareness & Training Security Incident Procedures Contingency Plans Evaluation Business Associate Agreements Facility Access Controls Workstation Use Workstation Security Device & Media Controls Device & Media Controls Access Control Audit Control Integrity Person or Entity Authentication Transmission Security Encryption 17

18 10 Best security practices for users 1. Unique user ID or log-in name (user access controls) 2. Password protection 3. Workstation security 4. Security for portable devices and laptops with e-phi 5. Data management and security 6. Secure remote access 7. security 8. Safe internet use 9. Limit instant messaging 10. Protection against malicious software 18

19 Final Omnibus Rules

20 Business associate changes Definition: Entities or people performing activities that involve use or disclosure of PHI for or on behalf of a covered entity The omnibus rules include several provisions that apply to business associates and covered entities that enter into agreements with them Revise the definition of business associate; and Assign direct BA liability Require changes to business associate agreements 20

21 Business associate definition changes A business associate now includes the following additional entities Patient safety organizations Health information organizations, e-prescribing gateways, and other organizations that transmit PHI to covered entity (or business associate) and that require access to PHI on a routine basis mere conduits that provide courier services excepted Data storage companies (whether digital, cloud, or hard copy) that maintain PHI, regardless of whether they require regular direct access Entities that offer personal health records (PHRs) to individuals on behalf of a covered entity 21

22 Subcontractors BA obligations and liability extend to subcontractors Covered entity is not required to enter a direct contract with the subcontractor Business associate must have a written agreement with its subcontractor containing satisfactory assurances that the subcontractor will comply with applicable provisions of the privacy and security rules Subcontractor noncompliance requires BA action 22

23 Business associates extension of liability Direct liability for compliance with certain HIPAA provisions, such as impermissible uses and disclosures and failure to: Provide a breach notification to the covered entity Provide access to a copy of electronic PHI Disclose PHI where required by HHS to investigate or determine compliance with HIPAA Provide an accounting of disclosures Comply with the requirements of the security rule Noncompliance with those rules could subject the business associate to civil and criminal penalties 23

24 Business associate agreements HHS has provided sample BAA language Among other things, BAAs must now state that business associates will: Comply with HIPAA s security rule Comply with the HITECH Act s privacy provisions (e.g., account for disclosures, follow minimum necessary rule, comply with revised sales and marketing rules) Comply with the HIPAA privacy rule to the same extent as the covered entity Report breaches of unsecured PHI to covered entities Ensure that subcontractors agree to the same restrictions as business associate 24

25 Business associate agreements Status of business associate agreement Actions Compliance date HIPAA-compliant agreement in effect before 1/25/2013 HIPAA-compliant agreement in effect before 1/25/2013 HIPAA-compliant agreement in effect before 1/25/2013 Renewed or modified on or after 1/25/2013 and before 3/26/2013 Renewed or modified on or after 3/26/2013 and before 9/23/2013 Renewed or modified on or after 9/23/2013 If evergreen or automatically renewed (i.e., no changes), no later than 9/22/2014 Otherwise unclear; conservatively, by 9/23/2013 9/23/2013 Earlier of renewal / modification date or 9/22/2014 New agreement executed in 2013 but before 9/23/2013 New agreement executed on or after 9/23/2013 9/23/2013 Effective date of agreement 25

26 Individual rights expanded Access to electronic records Restricted disclosures Decedent s PHI Proof of immunization 26

27 Use and disclosure of PHI coupled with financial remuneration Marketing Refill reminders or other communications about drug/biologicals Health-related products or services Government programs Communication about treatments and health care operations and recommendations of alternative treatments, providers, and therapies Case management Fundraising Opt out option Sale 27

28 HIPAA Enforcement and Breaches

29 What is a breach? Definition: acquisition, access, use or disclosure of PHI in an impermissible manner that compromises the security or privacy of the PHI New rules: Impermissible disclosure of PHI PRESUMED to be a breach Requires risk assessment of at least the following Nature and extent of PHI involved, including the types of identifiers and the likelihood of re-identification Who used or received the PHI Whether the PHI was actually acquired or viewed Any risk mitigation measures taken Burden on covered entity (the plan) or business associate to show no breach Notification within 60 days of discovery; sometimes to media 29

30 HITECH ups the ante Breach notifications Negative press Loss of employee or customer trust Administrative requirements to deal with breach notification Increased HIPAA civil penalties (that now apply to Business Associates too!) Violation Category Each Violation All Such Violations of an Identical Provision in a Calendar Year (A) Did Not Know $100 - $50,000 $1,500,000 (B) Reasonable Cause $1,000 - $50,000 $1,500,000 (C)(i) Willful Neglect-Corrected $10,000 - $50,000 $1,500,000 (C)(ii) Willful Neglect-Not Corrected $50,000 $1,500,000 Funds from penalties will be funneled into enforcement efforts Individuals harmed by HIPAA violations allowed to share in penalties State attorneys general given authority to bring civil actions in federal courts on behalf of their citizens 30

31 Enforcement HITECH requires HHS to provide for periodic compliance audits New protocols developed from pilot enforcement project will be applied going forward HHS HIPAA actions on the rise 31

32 Employer Action Items

33 Business associate issues Review HHS model BAA Revise BAAs to include the new direct liability provisions Determine date by which BAAs must be amended to comply with the omnibus rule Prepare an amendment for currently executed BAAs that adds the new provisions Consider changes to policies and procedures for monitoring business associate compliance to reflect the changes to the HIPAA enforcement rules 33

34 Notice of privacy practices Revise NPP to reflect the final omnibus rules Statement that covered entity is not permitted to use genetic information for underwriting purposes Statement regarding the covered entity s obligations to maintain the privacy of an individual s PHI Individual s right to receive notification in the event of a breach Individual s right to access electronic records Description of the uses and disclosures of PHI that require an authorization (e.g., use of psychotherapy notes, disclosure of PHI for marketing, and disclosures that constitute a sale of PHI) Statement regarding the covered entity s use of PHI for fundraising purposes and opt out rights 34

35 Notice of privacy practices A health plan that currently posts its NPP on its web site must: Prominently post the material change or the revised notice on its web site by September 23, 2013 Provide the revised notice (or information about the material change and how to obtain the revised notice) in its next annual mailing to covered individuals (e.g., open enrollment) If the health plan does not post the NPP on its web site, it must provide the revised NPP (or information about the material changes and how to get the full NPP) within 60 days of the material revision to the notice Due by Sept. 23,

36 Policies and procedures The definition of PHI includes genetic information Access to records can include PHI maintained electronically even if not an electronic health record A procedure is in place related to requested disclosures to third parties A provision is in place regarding handling of immunization records Breach notification reflects the new definition of breach Uses of genetic information are restricted How to respond to an individual s request to access electronic information How the plan will use or disclose decedent s PHI to family members and others involved in the care or payment of care 36

37 Policies and procedures Incorporate the new standards related to performing a risk assessment Correct definitions of marketing and sale are being used Include the permitted uses and disclosures related to marketing and sales (as applicable) Authorizations are updated for marketing and/or sale of PHI, if applicable If and how the entity will handle fundraising involving PHI (and a system for allowing individuals to opt out of fundraising communication) Permitted uses and disclosures for research are in place 37

38 HIPAA security Workforce training HIPAA Security Update HIPAA security policy and procedures Conduct comprehensive risk analysis Workforce training Update workforce training to include new provisions in the omnibus rules relevant to the group health plan, necessary changes to the organization s HIPAA policies and procedures, and breach notice training 38

39 Resources

40 Resources and how Buck can help Resources on Go to: Health and Productivity > HIPAA compliance Complimentary HIPAA Check-up HIPAA Training Program details FYI on HIPAA privacy and security regulations released 40

41 Questions?

42 Contacts Tami Simon, JD Managing Director, Knowledge Resource Center Washington, DC (202) Mary Harrison, JD Principal, Health and Productivity New York (212)

Protecting Patient Information in an Electronic Environment- New HIPAA Requirements

Protecting Patient Information in an Electronic Environment- New HIPAA Requirements Protecting Patient Information in an Electronic Environment- New HIPAA Requirements SD Dental Association Holly Arends, RHIT Clinical Program Manager Meet the Speaker TRUST OBJECTIVES Overview of HIPAA

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 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 and HITECH Compliance Under the New HIPAA Final Rule. HIPAA Final Omnibus Rule ( Final Rule )

HIPAA and HITECH Compliance Under the New HIPAA Final Rule. HIPAA Final Omnibus Rule ( Final Rule ) HIPAA and HITECH Compliance Under the New HIPAA Final Rule Presented Presented by: by: Barry S. Herrin, Attorney CHPS, Name FACHE Smith Smith Moore Moore Leatherwood Leatherwood LLP LLP Atlanta Address

More information

HHS announces sweeping changes to the HIPAA Privacy and Security Rules in the final HIPAA Omnibus Rule

HHS announces sweeping changes to the HIPAA Privacy and Security Rules in the final HIPAA Omnibus Rule JANUARY 23, 2013 HHS announces sweeping changes to the HIPAA Privacy and Security Rules in the final HIPAA Omnibus Rule By Linn Foster Freedman, Kathryn M. Sylvia, Lindsay Maleson, and Brooke A. Lane On

More information

Compliance Steps for the Final HIPAA Rule

Compliance Steps for the Final HIPAA Rule Brought to you by Cottingham & Butler for the Final HIPAA Rule On Jan. 25, 2013, the Department of Health and Human Services (HHS) issued a final rule under HIPAA s administrative simplification provisions.

More information

Updated HIPAA Regulations What Optometrists Need to Know Now. HIPAA Overview

Updated HIPAA Regulations What Optometrists Need to Know Now. HIPAA Overview Updated HIPAA Regulations What Optometrists Need to Know Now The U.S. Department of Health & Human Services Office for Civil Rights recently released updated regulations regarding the Health Insurance

More information

Final HIPAA/HITECH Omnibus Rule Makes Significant Changes for Health Plans and Their Business Associates

Final HIPAA/HITECH Omnibus Rule Makes Significant Changes for Health Plans and Their Business Associates Final HIPAA/HITECH Omnibus Rule Makes Significant Changes for Health Plans and Their Business Associates After a very long wait, the Department of Health and Human Services ( HHS ) has issued a final HIPAA/HITECH

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

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

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

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

FINAL HIPAA HITECH REGULATIONS RELEASED

FINAL HIPAA HITECH REGULATIONS RELEASED FINAL HIPAA HITECH REGULATIONS RELEASED On January 25, 2013, the United States Department of Health and Human Services (HHS) published final regulations implementing changes to the Health Insurance Portability

More information

Legislative & Regulatory Information

Legislative & Regulatory Information Americas - U.S. Legislative, Privacy & Projects Jurisdiction Effective Date Author Release Date File No. UFS Topic Citation: Reference: Federal 3/26/13 Michael F. Tietz Louis Enahoro HIPAA, Privacy, Privacy

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

HIPAA PRIVACY AND SECURITY FOR EMPLOYERS

HIPAA PRIVACY AND SECURITY FOR EMPLOYERS HIPAA PRIVACY AND SECURITY FOR EMPLOYERS Agenda Background and Enforcement HIPAA Privacy and Security Rules Breach Notification Rules HPID Number Why Does it Matter HIPAA History HIPAA Title II Administrative

More information

HIPAA Omnibus & HITECH Rules: Key Provisions and a Simple Checklist. www.riskwatch.com

HIPAA Omnibus & HITECH Rules: Key Provisions and a Simple Checklist. www.riskwatch.com HIPAA Omnibus & HITECH Rules: Key Provisions and a Simple Checklist www.riskwatch.com Introduction Last year, the federal government published its long awaited final regulations implementing the Health

More information

Key HIPAA HITECH Changes. Gina Kastel, Partner, Health and Life Sciences

Key HIPAA HITECH Changes. Gina Kastel, Partner, Health and Life Sciences Key HIPAA HITECH Changes Gina Kastel, Partner, Health and Life Sciences Agenda Business Associates Restrictions on Disclosures Access to PHI Notice of Privacy Practices Fundraising 2 Business Associates

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

DATA SHARING & BREACH PROTOCOLS UNDER THE FINAL HIPAA PRIVACY RULE

DATA SHARING & BREACH PROTOCOLS UNDER THE FINAL HIPAA PRIVACY RULE DATA SHARING & BREACH PROTOCOLS UNDER THE FINAL HIPAA PRIVACY RULE I. INTRODUCTION: The Health Insurance Portability and Accountability Act (HIPAA) Administrative Simplification provisions apply to three

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

HIPAA/HITECH Omnibus Final Rule - January 23, 2013

HIPAA/HITECH Omnibus Final Rule - January 23, 2013 HIPAA Omnibus Rule Please note: these slides are intended to provide an overview of general information, not an exhaustive review. No legal advice is being offered or intended. Do not rely on this information

More information

Regulatory Changes to HIPAA under HITECH and GINA

Regulatory Changes to HIPAA under HITECH and GINA HIPAA FINAL OMNIBUS RULE Fact Sheet Regulatory Changes to HIPAA under HITECH and GINA The U.S. Department of Health and Human Services released the Health Insurance Portability and Accountability Act (HIPAA)

More information

HIPAA & The Medical Practice

HIPAA & The Medical Practice HIPAA & The Medical Practice Requirements for Privacy, Security and Breach Notification Presented by: Gina L. Campanella, JD, MHA Rules that Control Privacy A collection of laws and regulations including:

More information

HIPAA Compliance Guide

HIPAA Compliance Guide HIPAA Compliance Guide Important Terms Covered Entities (CAs) The HIPAA Privacy Rule refers to three specific groups as covered entities, including health plans, healthcare clearinghouses, and health care

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

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

HIPAA Compliance Guide

HIPAA Compliance Guide HIPAA Compliance Guide Important Terms Covered Entities (CAs) The HIPAA Privacy Rule refers to three specific groups as covered entities, including health plans, healthcare clearinghouses, and health care

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

Business Associates and Breach Reporting Under HITECH and the Omnibus Final HIPAA Rule

Business Associates and Breach Reporting Under HITECH and the Omnibus Final HIPAA Rule Business Associates and Breach Reporting Under HITECH and the Omnibus Final HIPAA Rule Patricia D. King, Esq. Associate General Counsel Swedish Covenant Hospital Chicago, IL I. Business Associates under

More information

HIPAA Fundraising Fundamentals for Foundations WHA s 2013 Prescription for Success: A Workshop for Hospital Foundations August 13, 2013

HIPAA Fundraising Fundamentals for Foundations WHA s 2013 Prescription for Success: A Workshop for Hospital Foundations August 13, 2013 HIPAA Fundraising Fundamentals for Foundations WHA s 2013 Prescription for Success: A Workshop for Hospital Foundations August 13, 2013 Presented by: Monica C. Hocum, Esq. and Leia C. Olsen, Esq. Agenda

More information

Recent Changes to HIPAA Privacy Rule 2013 Omnibus Final Rule. Dennis Kennedy Dressman Benzinger LaVelle psc

Recent Changes to HIPAA Privacy Rule 2013 Omnibus Final Rule. Dennis Kennedy Dressman Benzinger LaVelle psc Recent Changes to HIPAA Privacy Rule 2013 Omnibus Final Rule Dennis Kennedy 859-426-2118 Dressman Benzinger LaVelle psc dkennedy@dbllaw.com What's the effect of most HIPAA presentations? HIPAA-nosis Multiple

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 The Workplace. What Every Employee Should Know and Remember

HIPAA In The Workplace. What Every Employee Should Know and Remember HIPAA In The Workplace What Every Employee Should Know and Remember What is HIPAA? The Health Insurance Portability and Accountability Act of 1996 Portable Accountable Rules for Privacy Rules for Security

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

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 MC Academy The Employee Benefits and Executive Compensation Series. HIPAA PRIVACY AND SECURITY The New Final Regulations

The MC Academy The Employee Benefits and Executive Compensation Series. HIPAA PRIVACY AND SECURITY The New Final Regulations The MC Academy The Employee Benefits and Executive Compensation Series HIPAA PRIVACY AND SECURITY The New Final Regulations June 18, 2013 Overview Background Recent Changes to HIPAA Identifying Business

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

M E M O R A N D U M. Leon Rodriguez, HHS Office for Civil Rights Director, noted in a press release that the Omnibus Rule:

M E M O R A N D U M. Leon Rodriguez, HHS Office for Civil Rights Director, noted in a press release that the Omnibus Rule: To: From: Clients and Friends Jim Pyles Rob Portman Amita Sanghvi M E M O R A N D U M REVISED/UPDATED Date: January 25, 2013 Re: HIPAA Final Omnibus Rule is Here! On January 17, 2013, the US Department

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

HIPAA Omnibus Compliance How A Data Loss Prevention Solution Can Help

HIPAA Omnibus Compliance How A Data Loss Prevention Solution Can Help HIPAA Omnibus Compliance How A Data Loss Prevention Solution Can Help The Health Information Portability and Accountability Act (HIPAA) Omnibus Rule which will begin to be enforced September 23, 2013,

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

ü Ensuring the privacy and security of personally identifiable health information (the Privacy and Security Rules); and

ü Ensuring the privacy and security of personally identifiable health information (the Privacy and Security Rules); and Provided by Benefits By Choice HIPAA Rules: Privacy, Security and Electronic Data Interchange The Health Insurance Portability and Accountability Act of 1996 (HIPAA) is a broad federal law regarding health

More information

HIPAA RISKS & STRATEGIES. Health Insurance Portability and Accountability Act of 1996

HIPAA RISKS & STRATEGIES. Health Insurance Portability and Accountability Act of 1996 HIPAA RISKS & STRATEGIES Health Insurance Portability and Accountability Act of 1996 REGULATORY BACKGROUND Health Information Portability and Accountability Act (HIPAA) was enacted on August 21, 1996 Title

More information

BREVIUM HIPAA BUSINESS ASSOCIATE TERMS AND CONDITIONS

BREVIUM HIPAA BUSINESS ASSOCIATE TERMS AND CONDITIONS BREVIUM HIPAA BUSINESS ASSOCIATE TERMS AND CONDITIONS The following HIPAA Business Associate Terms and Conditions (referred to hereafter as the HIPAA Agreement ) are part of the Brevium Software License

More information

The Basics of HIPAA Privacy and Security and HITECH

The Basics of HIPAA Privacy and Security and HITECH The Basics of HIPAA Privacy and Security and HITECH Protecting Patient Privacy Disclaimer The content of this webinar is to introduce the principles associated with HIPAA and HITECH regulations and is

More information

HIPAA Compliance Review

HIPAA Compliance Review HIPAA Compliance Review For HR and IT Presented by: Linda Railton, PHR HR Consultant Leavitt Group linda.railton@leavitt.com Discussion Points HIPAA Final Rule (effective March 26, 2013) Overview of HIPAA

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

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

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

This presentation focuses on the Healthcare Breach Notification Rule. First published in 2009, the final breach notification rule was finalized in

This presentation focuses on the Healthcare Breach Notification Rule. First published in 2009, the final breach notification rule was finalized in This presentation focuses on the Healthcare Breach Notification Rule. First published in 2009, the final breach notification rule was finalized in the HIPAA Omnibus Rule of 2013. As part of the American

More information

HIPAA Update. Presented by: Melissa M. Zambri. June 25, 2014

HIPAA Update. Presented by: Melissa M. Zambri. June 25, 2014 HIPAA Update Presented by: Melissa M. Zambri June 25, 2014 Timeline of New Rules 2/17/09 - Stimulus Package Enacted 8/24/09 - Interim Final Rule on Breach Notification 10/7/09 - Proposed Rule Regarding

More information

Presented by Jack Kolk President ACR 2 Solutions, Inc.

Presented by Jack Kolk President ACR 2 Solutions, Inc. HIPAA 102 : What you don t know about the new changes in the law can hurt you! Presented by Jack Kolk President ACR 2 Solutions, Inc. Todays Agenda: 1) Jack Kolk, CEO of ACR 2 Solutions a information security

More information

HIPAA, HIPAA Hi-TECH and HIPAA Omnibus Rule

HIPAA, HIPAA Hi-TECH and HIPAA Omnibus Rule HIPAA, HIPAA Hi-TECH and HIPAA Omnibus Rule NYCR-245157 HIPPA, HIPAA HiTECH& the Omnibus Rule A. HIPAA IIHI and PHI Privacy & Security Rule Covered Entities and Business Associates B. HIPAA Hi-TECH Why

More information

C.T. Hellmuth & Associates, Inc.

C.T. Hellmuth & Associates, Inc. Technical Monograph C.T. Hellmuth & Associates, Inc. Technical Monographs usually are limited to only one subject which is treated in considerably more depth than is possible in our Executive Newsletter.

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

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

AVE MARIA UNIVERSITY HIPAA PRIVACY NOTICE

AVE MARIA UNIVERSITY HIPAA PRIVACY NOTICE AVE MARIA UNIVERSITY HIPAA PRIVACY NOTICE This Notice of Privacy Practices describes the legal obligations of Ave Maria University, Inc. (the plan ) and your legal rights regarding your protected health

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

SaaS. Business Associate Agreement

SaaS. Business Associate Agreement SaaS Business Associate Agreement This Business Associate Agreement ( BA Agreement ) becomes effective pursuant to the terms of Section 5 of the End User Service Agreement ( EUSA ) between Customer ( Covered

More information

What Health Care Entities Need to Know about HIPAA and the American Recovery and Reinvestment Act

What Health Care Entities Need to Know about HIPAA and the American Recovery and Reinvestment Act What Health Care Entities Need to Know about HIPAA and the American Recovery and Reinvestment Act by Lane W. Staines and Cheri D. Green On February 17, 2009, The American Recovery and Reinvestment Act

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 Policy, Protection, and Pitfalls ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS

HIPAA Policy, Protection, and Pitfalls ARTHUR J. GALLAGHER & CO. BUSINESS WITHOUT BARRIERS HIPAA Policy, Protection, and Pitfalls Overview HIPAA Privacy Basics What s covered by HIPAA privacy rules, and what isn t? Interlude on the Hands-Off Group Health Plan When does this exception apply,

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

HIPAA/HITECH and Texas Privacy Laws Comparison Tool Updated 2013

HIPAA/HITECH and Texas Privacy Laws Comparison Tool Updated 2013 HIPAA/HITECH and Texas Privacy Laws Comparison Tool Updated 2013 Federal and Texas Privacy & Security Requirements Minimizing Your Risk of Violations DISCLAIMER The information contained in this document

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

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 Business Associate Addendum

HIPAA Business Associate Addendum HIPAA Business Associate Addendum THIS HIPAA BUSINESS ASSOCIATE ADDENDUM (this Addendum ) is by and between ( Covered Entity ) and TALKSOFT CORPORATION ( Business Associate ) (hereinafter, Covered Entity

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

SECURITY RISK ASSESSMENT SUMMARY

SECURITY RISK ASSESSMENT SUMMARY Providers Business Name: Providers Business Address: City, State, Zip Acronyms NIST FIPS PHI EPHI BA CE EHR HHS IS National Institute of Standards and Technology Federal Information Process Standards Protected

More information

HIPAA Privacy and Security Rules: A Refresher. Marilyn Freeman, RHIA California Area HIPAA Coordinator California Area HIM Consultant

HIPAA Privacy and Security Rules: A Refresher. Marilyn Freeman, RHIA California Area HIPAA Coordinator California Area HIM Consultant HIPAA Privacy and Security Rules: A Refresher Marilyn Freeman, RHIA California Area HIPAA Coordinator California Area HIM Consultant Objectives Provide overview of Health insurance Portability and Accountability

More information

HIPAA Compliance, Notification & Enforcement After The HITECH Act. Presenter: Radha Chanderraj, Esq.

HIPAA Compliance, Notification & Enforcement After The HITECH Act. Presenter: Radha Chanderraj, Esq. HIPAA Compliance, Notification & Enforcement After The HITECH Act Presenter: Radha Chanderraj, Esq. Key Dates Publication date January 25, 2013 Effective date - March 26, 2013 Compliance date - September

More information

HIPAA Breach Notification Interim Final Rule

HIPAA Breach Notification Interim Final Rule HIPAA Breach Notification Interim Final Rule The American Recovery and Reinvestment Act of 2009 ( the Act ) made several changes to the HIPAA privacy rules including adding a requirement for notice to

More information

HHS Issues HIPAA/HITECH Omnibus Final Rule Ushering in Significant Changes to Ex... Page 1 of 10 Related Individuals Richard J Zall Partner t: 212.969.3945 Edward S Kornreich Partner t: 212.969.3395 Kristen

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

Datto Compliance 101 1

Datto Compliance 101 1 Datto Compliance 101 1 Overview Overview This document provides a general overview of the Health Insurance Portability and Accounting Act (HIPAA) compliance requirements for Managed Service Providers (MSPs)

More information

Joseph Suchocki HIPAA Compliance 2015

Joseph Suchocki HIPAA Compliance 2015 Joseph Suchocki HIPAA Compliance 2015 Sponsored by Eagle Associates, Inc. Eagle Associates provides compliance services for over 1,200 practices nation wide. Services provided by Eagle Associates address

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

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

Final Rule: Modifications to the HIPAA Privacy, Security, Enforcement, and HITECH Act Breach Notification Rules, 78 Fed. Reg. 5566 (Jan.

Final Rule: Modifications to the HIPAA Privacy, Security, Enforcement, and HITECH Act Breach Notification Rules, 78 Fed. Reg. 5566 (Jan. AIS Special Report 1 AIS Special Report Final Rule: Modifications to the HIPAA Privacy, Security, Enforcement, and HITECH Act Breach Notification Rules, 78 Fed. Reg. 5566 (Jan. 25, 2013) By Francie Fernald,

More information

ACKNOWLEDGMENT OF RECEIPT OF NOTICE OF PRIVACY PRACTICES

ACKNOWLEDGMENT OF RECEIPT OF NOTICE OF PRIVACY PRACTICES ACKNOWLEDGMENT OF RECEIPT OF NOTICE OF PRIVACY PRACTICES I acknowledge that I have been provided a copy of Fiorillo Cosmetic and General Dentistry s Notice of Privacy Practices, which has an effective

More information

Long-Expected Omnibus HIPAA Rule Implements Significant Privacy and Security Regulations for Entities and Business Associates

Long-Expected Omnibus HIPAA Rule Implements Significant Privacy and Security Regulations for Entities and Business Associates Legal Update February 11, 2013 Long-Expected Omnibus HIPAA Rule Implements Significant Privacy and Security Regulations for Entities and Business Associates On January 17, 2013, the Department of Health

More information

Penalty. Conduct of covered entity or business associate. Did not know and, by exercising reasonable diligence, would not have known of the violation

Penalty. Conduct of covered entity or business associate. Did not know and, by exercising reasonable diligence, would not have known of the violation WHY YOU NEED TO COMPLY. HIPAA UPDATE 2014: WHY AND HOW YOU MUS T C OMPL Y 1 In January 2013, the Department of Health and Human Services ( HHS ) issued its longawaited Omnibus Rule 2 implementing regulations

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

Policies and Procedures Audit Checklist for HIPAA Privacy, Security, and Breach Notification

Policies and Procedures Audit Checklist for HIPAA Privacy, Security, and Breach Notification Policies and Procedures Audit Checklist for HIPAA Privacy, Security, and Breach Notification Type of Policy and Procedure Comments Completed Privacy Policy to Maintain and Update Notice of Privacy Practices

More information

HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA) TERMS AND CONDITIONS FOR BUSINESS ASSOCIATES

HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA) TERMS AND CONDITIONS FOR BUSINESS ASSOCIATES HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA) TERMS AND CONDITIONS FOR BUSINESS ASSOCIATES I. Overview / Definitions The Health Insurance Portability and Accountability Act is a federal law

More information

January 25, 2013. 1 P a g e

January 25, 2013. 1 P a g e Analysis of Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules under the Health Information Technology for Economic and Clinical Health Act and the Genetic Information

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

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

Health Insurance Portability and Accountability Act (HIPAA) and Health Information Technology for Economic and Clinical Health Act (HITECH)

Health Insurance Portability and Accountability Act (HIPAA) and Health Information Technology for Economic and Clinical Health Act (HITECH) Health Insurance Portability and Accountability Act (HIPAA) and Health Information Technology for Economic and Clinical Health Act (HITECH) Table of Contents Introduction... 1 1. Administrative Safeguards...

More information

What is HIPAA? The Health Insurance Portability and Accountability Act of 1996

What is HIPAA? The Health Insurance Portability and Accountability Act of 1996 What is HIPAA? The Health Insurance Portability and Accountability Act of 1996 BASIC QUESTIONS AND ANSWERS What Does HIPAA do? Creates national standards to protect individuals' medical records and other

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

Breaches. Complying with the HIPAA Omnibus Final Rule. Important Definitions. Protected Health Information Includes HIPAA PRIVACY 3/2/2014

Breaches. Complying with the HIPAA Omnibus Final Rule. Important Definitions. Protected Health Information Includes HIPAA PRIVACY 3/2/2014 Breaches Complying with the HIPAA Omnibus Final Rule You Can Be Successful! Advocate Medical Group in Chicago had 4 desktop computers taken in a burglary that contained the personal information of over

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

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/HITECH PRIVACY & SECURITY CHECKLIST SELF ASSESSMENT INSTRUCTIONS

HIPAA/HITECH PRIVACY & SECURITY CHECKLIST SELF ASSESSMENT INSTRUCTIONS HIPAA/HITECH PRIVACY & SECURITY CHECKLIST SELF ASSESSMENT INSTRUCTIONS Thank you for taking the time to fill out the privacy & security checklist. Once completed, this checklist will help us get a better

More information

Covered Entities and Business Associates: An Evolving Relationship

Covered Entities and Business Associates: An Evolving Relationship Covered Entities and Business Associates: An Evolving Relationship Rebecca L. Williams, RN, JD Partner, Chair of HEALTH/HIPAA Practice Davis Wright Tremaine LLP beckywilliams@dwt.com 1 No health care provider

More information

BUSINESS ASSOCIATE AGREEMENT

BUSINESS ASSOCIATE AGREEMENT BUSINESS ASSOCIATE AGREEMENT This Business Associate Agreement ( Agreement ) between Inphonite, LLC ( Business Associate and you, as our Customer ( Covered Entity ) (each individually, a Party, and collectively,

More information

HIPAA Update Focus on Breach Prevention

HIPAA Update Focus on Breach Prevention HIPAA Update Focus on Breach Prevention Objectives By the end of this program, participants should be able to: Identify top reasons why breaches occur Review the breach definition and notification process

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