Business Associate Risk
|
|
- Candice Cooper
- 5 years ago
- Views:
Transcription
1 Business Associate Risk Assessing and Managing Business Associate Risk Presented by CJ Wolf, MD, COC, CPC, CHC, CCEP, CIA Healthicity Senior Compliance Executive Disclaimer: Nothing in this presentation should be construed as legal advice nor replied upon as legal expertise. 1
2 Breaches of 500+ individuals As required by section 13402(e)(4) of the HITECH Act, the HHS must post a list of breaches of unsecured protected health information affecting 500 or more individuals. As of Feb approximately 20% were due to business associates 2
3 RevSpring, Inc. 3,000 individuals Due to a printing error at the covered entity s (CE) business associate (BA), patients received billing statements containing other patients protected health information (PHI). The breach included names, account numbers, balances owed, procedure codes and descriptions, provider names, and dates of services. Following the breach, the CE obtained assurances from its BA that additional safeguards were implemented to prevent future disclosures. As a result of OCR s investigation, OCR reviewed the CE s policies and procedures to ensure compliance with the HIPAA Rules and reviewed the breach notification provided to affected individuals and the media. 3
4 4
5 KPMG LLP An employee of Newark Beth Israel Medical Center business associate (BA), KPMG LLP, lost an unencrypted USB drive that contained the electronic protected health information (ephi) of 956 individuals. The ephi included names and clinical information. The CE provided breach notification to HHS, the Media and affected individuals. As a result of OCR's investigation, the BA installed and implemented encryption software to its electronic equipment and devices. In addition, the BA encrypted and password protected all equipment and devices that could contain the CE's data. The BA also reprimanded and retrained the employee and retrained all employees on safeguarding ephi. 5
6 Global Care Delivery Five password-protected, but unencrypted laptop computers were stolen from Global Care Delivery, a business associate (BA) of the covered entity (CE), North Shore LIJ Health System The laptops contained the protected health information (PHI) of 18,213 individuals, including names, dates of birth, insurance identification numbers (which contained social security numbers), and diagnoses and/or treatment codes related to claims. The BA notified police at the time of the incident, but did not notify the CE until May 11, The business relationship between the CE and BA ended effective May 11, The BA has closed its business. 6
7 E-dreamz The credit card information of 9,988 patients of the covered entity (CE), Presbyterian Anesthesia Associates, P.A. (now known as Providence Anesthesia Associates, P.A.), was compromised when an unauthorized person gained access to the servers of E-dreamz, the CE s website hosting business associate (BA). The CE provided breach notification to HHS, the media, and affected individuals, and offered them a year of free credit monitoring and identity theft protection. In response to the breach, the CE hired an outside forensic computer specialist to investigate. Additionally, the CE terminated its service agreement with the BA and entered into a satisfactory BA agreement with a new website hosting vendor. The BA agreement prohibits storage of any PHI on the vendor s servers. The CE also reviewed and updated its HIPAA policies and procedures. 7
8 Dr. Veronica Joann Barber Veronica Joann Barber, O.D., (VB) copied the covered entity s (CE) entire data base and used the electronic protected health information (ephi) to solicit patients for her own practice. VB worked at the CE s office under a space-sharing agreement until the CE terminated the agreement. The CE requested that VB cease and desist using the PHI, but she did not agree. The theft occurred on December 15, 2013, and affected 4,000 individuals. The ephi involved in the breach included individuals names, social security numbers, addresses, driver s licenses, dates of births, other identifiers, credit card and bank account numbers, claims information, other financial information, diagnoses and medical conditions, medications, and other treatment information. The CE provided breach notification to HHS and affected individuals. Following the breach the CE installed computer firewalls. Based on OCR s provision of technical assistance, the CE notified the media and completed a risk assessment. It also improved safeguards by denying access by unlicensed persons to its computer systems and updating its policies and procedures regarding computer user names and passwords. The CE improved physical safeguards by moving the computer with the ephi behind a 5-foot tall counter. Pharmacy Chain Enters into Business Associate Agreement with Law Firm Covered Entity: Pharmacy Chain Issue: Impermissible Uses and Disclosures; Business Associates A complaint alleged that a law firm working on behalf of a pharmacy chain in an administrative proceeding impermissibly disclosed the PHI of a customer of the pharmacy chain. OCR investigated the allegation and found no evidence that the law firm had impermissibly disclosed the customer s PHI. However, the investigation revealed that the pharmacy chain and the law firm had not entered into a Business Associate Agreement, as required by the Privacy Rule to ensure that PHI is appropriately safeguarded. Without a properly executed agreement, a covered entity may not disclose PHI to its law firm. To resolve the matter, OCR required the pharmacy chain and the law firm to enter into a business associate agreement. 8
9 Steps to Protect Yourself Assess Business Associate s Preparedness/Exposure (due diligence) Contractual Protections Specificity of Tasks and Requirements (Statement of Work) 9
10 Has the BA performed a risk analysis? When? What were the results? What reasonably anticipated threats to ephi and system vulnerabilities were identified? What were the top 3 risks identified? What mitigation steps have been taken to identify the risks? Does the BA have a written privacy policy? Are employees required to attest to policy annually? Does the BA have a privacy officer? Are the privacy duties part-time? Are the privacy duties full-time? Is the privacy officer a high level employee? 10
11 Does the BA have a written security policy? Are employees required to attest to policy annually? Does the BA have a security officer (HPI)? Are the security duties part-time? Are the security duties full-time? Is the security officer a high level employee? Does the BA require employees to complete HIPAA training? Is completion of the training documented? Must the training be completed before the employee is given access to functions that expose PHI? 11
12 Has the BA proactively had an independent third party audit of their HIPAA compliance program? When? What were the results? What were the top 3 risks identified? What mitigation steps have been taken to identify the risks? Was penetration testing performed? Encryption: What are the encryption levels? Are all portable devices encrypted? Mobile Phones? Laptops? Tablets? Portable flash drives/usb drives? 12
13 What is the documented communication plan if contacted by OCR or other regulatory body? Does it include timely deadlines for contacting the CE? Who will be contacted? How? What is the documented plan for a breach? Is there a written policy that incorporates Breach Notification Rules? What are the physical security standards for all the sites of the BA? Does the BA have a written procedure for compliant destruction of PHI? Has the CE reviewed the procedure? 13
14 Compliance Manager Total Management Complete Guidance Affordable for Everyone Bonus Resources Compliance Services Leverage an Expert Optimize Revenue Improve Accuracy Save Time 14
15 Questions? 15
Determining Whether You Are a Business Associate
The HIPAApotamus in the Room: When Lawyers and Law Firms are Subject to HIPAA Enforcement, And How to Comply with the Law by Leslie R. Isaacman, J.D., M.B.A. The Omnibus Final Rule 1 of the Health Information
More informationARE YOU HIP WITH HIPAA?
ARE YOU HIP WITH HIPAA? Scott C. Thompson 214.651.5075 scott.thompson@haynesboone.com February 11, 2016 HIPAA SECURITY WHY SHOULD I CARE? Health plan fined $1.2 million for HIPAA breach. Health plan fined
More informationHIPAA Overview Health Insurance Portability and Accountability Act. Premier Senior Marketing, Inc
HIPAA Overview Health Insurance Portability and Accountability Act Premier Senior Marketing, Inc HIPAA Defined Acronym that stands for the Health Insurance Portability and Accountability Act, a US law
More informationHIPAA AND YOU 2017 G E R A L D E MELTZER, MD MSHA
HIPAA AND YOU 2017 G E R A L D E MELTZER, MD MSHA ALLISON SHUREN, J D, MSN Financial Disclosure Gerald Meltzer is a consultant for imedicware Allison Shuren co-chairs the Life Sciences and Healthcare Regulatory
More information503 SURVIVING A HIPAA BREACH INVESTIGATION
503 SURVIVING A HIPAA BREACH INVESTIGATION Presented by Nicole Hughes Waid, Esq. Mark J. Swearingen, Esq. Celeste H. Davis, Esq. Regional Manager 1 Surviving a HIPAA Breach Investigation: Enforcement Presented
More informationAFTER THE OMNIBUS RULE
AFTER THE OMNIBUS RULE 1 Agenda Omnibus Rule Business Associates (BAs) Agreement Breach Notification Change Breach Reporting Requirements (Federal and State) Notification to Care1st Health Plan Member
More informationHEALTHCARE BREACH TRIAGE
IAPP Privacy Academy September 30 October 2, 2013 HEALTHCARE BREACH TRIAGE Theodore P. Augustinos EDWARDS WILDMAN PALMER LLP Kenneth P. Mortensen CVS/CAREMARK 2013 Edwards Wildman Palmer LLP & Edwards
More informationHIPAA in the Digital Age. Anisa Kelley and Rachel Procopio Maryan Rawls Law Group Fairfax, Virginia
HIPAA in the Digital Age Anisa Kelley and Rachel Procopio Maryan Rawls Law Group Fairfax, Virginia Virginia MGMA reminds attendees that the program is not intended to provide legal advice and advises participants
More informationPreparing for a HIPAA Audit & Hot Topics in Health Care Reform
Preparing for a HIPAA Audit & Hot Topics in Health Care Reform 2013 San Francisco Mid-Sized Retirement & Healthcare Plan Management Conference March 17-20, 2013 Elizabeth Loh, Esq. Copyright Trucker Huss,
More informationHIPAA. What s New & What Do I Have To Do? Presented by Leslie Canham, CDA, RDA, CSP (Certified Speaking Professional)
HIPAA Infection Control OSHA Dental Practice Act HIPAA What s New & What Do I Have To Do? Presented by Leslie Canham, CDA, RDA, CSP (Certified Speaking Professional) In the dental field since 1972, Leslie
More informationLEGAL ISSUES IN HEALTH IT SECURITY
LEGAL ISSUES IN HEALTH IT SECURITY Webinar Hosted by Uluro, a Product of Transformations, Inc. March 28, 2013 Presented by: Kathie McDonald-McClure, Esq. Wyatt, Tarrant & Combs, LLP 500 West Jefferson
More informationThe Impact of Final Omnibus HIPAA/HITECH Rules. Presented by Eileen Coyne Clark Niki McCoy September 19, 2013
The Impact of Final Omnibus HIPAA/HITECH Rules Presented by Eileen Coyne Clark Niki McCoy September 19, 2013 0 Disclaimer The material in this presentation is not meant to be construed as legal advice
More informationHIPAA Data Breach ITPC
HIPAA Data Breach Objectives Overview of Omnibus Rule - Data Breach Suspected Breach - Investigation Audit Risk Assessment Corrective Action Plan Written Notification Elements NYS Rules on Data Breach
More information6/7/2018. HIPAA Compliance Simplified. HHS Wall of Shame. Marc Haskelson, President Compliancy Group
855 85 HIPAA (855-854-4722) www.compliancygroup.com 1 HIPAA Compliance Simplified Marc Haskelson, President Compliancy Group Agenda Why HIPAA? Common misunderstandings What is a Audit? Real World Stories
More informationPrivacy Rule - Complaint Investigations
Update on Enforcement of the HIPAA Privacy and Security Rules Marilou King, JD Office for Civil Rights U.S. Department of Heath and Human Services www.hcca-info.org 888-580-8373 Privacy Rule - Complaint
More informationHIPAA AND ONLINE BACKUP WHAT YOU NEED TO KNOW ABOUT
WHAT YOU NEED TO KNOW ABOUT HIPAA AND ONLINE BACKUP Learn more about how KeepItSafe can help to reduce costs, save time, and provide compliance for online backup, disaster recovery-as-a-service, mobile
More informationHIPAA COMPLIANCE ROADMAP AND CHECKLIST FOR BUSINESS ASSOCIATES
HIPAA COMPLIANCE ROADMAP AND CHECKLIST FOR BUSINESS ASSOCIATES The Health Information Technology for Economic and Clinical Health Act (HITECH Act), enacted as part of the American Recovery and Reinvestment
More informationTo: Our Clients and Friends January 25, 2013
Life Sciences and Health Care Client Service Group To: Our Clients and Friends January 25, 2013 Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules under the Health
More informationHEALTH & HUMAN SERVICES OFFICE FOR CIVIL RIGHTS HIPAA COMPLIANCE AUDITS. What do I need to know?
HEALTH & HUMAN SERVICES OFFICE FOR CIVIL RIGHTS HIPAA COMPLIANCE AUDITS What do I need to know? INITIAL AUDITS PERFORMED IN 2016 Covered Entities Business associates AUDIT PURPOSE: SUPPORT IMPROVED COMPLIANCE
More information8/14/2013. HIPAA Privacy & Security 2013 Omnibus Final Rule update. Highlights from Final Rules January 25, 2013
HIPAA Privacy & Security 2013 Omnibus Final Rule update Dan Taylor, Infinisource Copyright 2013 All rights reserved. Highlights from Final Rules January 25, 2013 Made business associates directly liable
More information2016 Business Associate Workforce Member HIPAA Training Handbook
2016 Business Associate Workforce Member HIPAA Training Handbook Using the Training Handbook The material in this handbook is designed to deliver required initial, and/or annual HIPAA training for all
More informationManagement Alert Final HIPAA Regulations Issued
Management Alert Final HIPAA Regulations Issued After much anticipation, the Department of Health and Human Services (HHS) has issued its omnibus set of final regulations modifying and clarifying the privacy,
More informationCoping with, and Taking Advantage of, HIPAA s New Rules!! Deven McGraw Director, Health Privacy Project April 19, 2013!
Coping with, and Taking Advantage of, HIPAA s New Rules!!! Deven McGraw Director, Health Privacy Project April 19, 2013! Status of Federal Privacy Regulations! Omnibus Rule (Data Breach, Enforcement, HITECH,
More informationNew. To comply with HIPAA notice requirements, all Providence covered entities shall follow, at a minimum, the specifications described below.
Subject: Protected Health Information Breach Notification Policy Department: Enterprise Risk Management Services Executive Sponsor: SVP/Chief Risk Officer Approved by: Rod Hochman, MD President/CEO Policy
More informationHIPAA Compliance Guide
This document provides an overview of the Health Insurance Portability and Accountability Act (HIPAA) compliance requirements. It covers the relevant legislation, required procedures, and ways that your
More informationHIPAA Training. HOPE Health Facility Administrators June 2013 Isaac Willett and Jason Schnabel
HIPAA Training HOPE Health Facility Administrators June 2013 Isaac Willett and Jason Schnabel Agenda HIPAA basics HITECH highlights Questions and discussion HIPAA Basics Legal Basics Health Insurance Portability
More informationSafeguarding Your HIPAA and Personal Health Information Data. Robert Hess, Office of General Counsel Steve Cosentino, Stinson Morrison Hecker
Safeguarding Your HIPAA and Personal Health Information Data Robert Hess, Office of General Counsel Steve Cosentino, Stinson Morrison Hecker 1 Overview» Patient information confidentiality Grant requirements
More informationHIPAA Update. Jamie Sorley U.S. Department of Health and Human Services Office for Civil Rights
HIPAA Update Jamie Sorley U.S. Department of Health and Human Services Office for Civil Rights New Mexico Health Information Management Association Conference April 11, 2014 Albuquerque, NM Recent Enforcement
More informationHIPAA Privacy, Breach, & Security Rules
HIPAA Privacy, Breach, & Security Rules An Eagle Associates Presentation Eagle Associates, Inc. www.eagleassociates.net info@eagleassociates.net P.O. Box 1356 Ann Arbor, MI 48106 800-777-2337 Eagle Associates,
More informationKey Legal Issues in EMR, EMR Subsidy and HIPAA and Privacy Click Issues to edit Master title style
Key Legal Issues in EMR, EMR Subsidy and HIPAA and Privacy Click Issues to edit Master title style July 27, 2016 www.mcguirewoods.com Introductions Holly Carnell McGuireWoods LLP hcarnell@mcguirewoods.com
More informationOMNIBUS RULE ARRIVES
AFTER THE OMNIBUS RULE 1 Agenda Omnibus Rule is here Business Associates (BAs) Agreement Breach Notification Change Breach Reporting Requirements (Federal and State) Notification to Care1st Health Plan
More informationGetting a Grip on HIPAA
Getting a Grip on HIPAA Privacy and Security of Health Information in the Post-HITECH Age Jean C. Hemphill hemphill@ballardspahr.com 215.864.8539 Edward I. Leeds leeds@ballardspahr.com 215.864.8419 Amy
More informationHIPAA: Impact on Corporate Compliance
HIPAA: Impact on Corporate Compliance AAPC HEALTHCON April 2014 Stacy Harper, JD, MHSA, CPC Disclaimer The information provided is for educational purposes only and is not intended to be considered legal
More informationHIPAA Omnibus Rule. Critical Changes for Providers Presented by Susan A. Miller, JD. Hosted by
HIPAA Omnibus Rule Critical Changes for Providers Presented by Susan A. Miller, JD Hosted by agenda What the Omnibus Rule includes + Effective and Compliance Dates Security Breach Notification Enforcement
More informationHIPAA: Final Omnibus Rule is Here Arizona Society for Healthcare Risk Managers November 15, 2013
HIPAA: Final Omnibus Rule is Here Arizona Society for Healthcare Risk Managers November 15, 2013 Pat Henrikson, Banner Health HIPAA Compliance Program Director, Chief Privacy Officer Agenda Background
More informationPriciest HIPAA Incidents of 2015
Priciest HIPAA Incidents of 2015 Cornell Prescription Pharmacy - $125,000 Cornell Prescription Pharmacy, a Denver-based pharmacy specializing in compounded medications, was ordered to pay $125,000 due
More informationUnderstanding Cyber Risk in the Dental Office. Melissa Moore Sanchez, CIC
Understanding Cyber Risk in the Dental Office Melissa Moore Sanchez, CIC Data Breaches are Escalating Between February 5, 2005 and May 26, 2012 561,465,563 records containing sensitive personal information
More informationHIPAA THE NEW RULES. Highlights of the major changes under the Omnibus Rule
HIPAA THE NEW RULES Highlights of the major changes under the Omnibus Rule AUTHOR Gamelah Palagonia, Founder CIPM, CIPP/IT, CIPP/US, CIPP/G, ARM, RPLU+ PRIVACY PROFESSIONALS LLC gpalagonia@privacyprofessionals.com
More information2011 Miller Johnson. All rights reserved. 1. HIPAA Compliance: Privacy and Security Changes under HITECH HITECH. What is HITECH? Mary V.
HIPAA Compliance: Privacy and Security Changes under HITECH Mary V. Bauman www.millerjohnson.com The materials and information have been prepared for informational purposes only. This is not legal advice,
More informationSaturday, April 28 Medical Ethics: HIPAA Privacy and Security Rules
Saturday, April 28 Medical Ethics: HIPAA Privacy and Security Rules Gina Campanella, JD HIPAA & The Medical Practice Requirements for Privacy, Security and Breach Notification Gina L. Campanella, Esq.
More informationGUIDANCE ON HIPAA & CLOUD COMPUTING
GUIDANCE ON HIPAA & CLOUD COMPUTING http://www.hhs.gov/hipaa/for-professionals/special-topics/cloudcomputing/index.html January 26, 2017 Health Care Cloud Coalition Deven McGraw, Deputy Director, Health
More informationHIPAA UPDATE/ OCR ENFORCEMENT
HEALTH CARE COMPLIANCE ASSOCIATION HIPAA UPDATE/ OCR ENFORCEMENT HCCA REGIONAL CONFERENCE East Central Region Michael A. Cassidy, Esquire October 14, 2011 Copyright Tucker Arensberg, P.C. All Rights Reserved.
More informationH E A L T H C A R E L A W U P D A T E
L O U I S V I L L E. K Y S E P T E M B E R 2 0 0 9 H E A L T H C A R E L A W U P D A T E L E X I N G T O N. K Y B O W L I N G G R E E N. K Y N E W A L B A N Y. I N N A S H V I L L E. T N M E M P H I S.
More informationLegal and Privacy Implications of the HIPAA Final Omnibus Rule
Legal and Privacy Implications of the HIPAA Final Omnibus Rule February 19, 2013 Pillsbury Winthrop Shaw Pittman LLP Faculty Gerry Hinkley Partner Pillsbury Winthrop Shaw Pittman LLP Deven McGraw Director,
More informationHIPAA / HITECH. Ed Massey Affiliated Marketing Group
HIPAA / HITECH Agent Understanding And Compliance Presented By: Ed Massey Affiliated Marketing Group It s The Law On February 17, 2010 the Health Information Technology for Economic and Clinical Health
More informationHIPAA Compliance Under the Magnifying Glass
HIPAA Compliance Under the Magnifying Glass July 30, 2013 Stacy Harper, JD, MHSA, CPC A Webinar Provided by Presenter Stacy Harper Lathrop & Gage, LLP sharper@lathropgage.com 913-451-5125 The information
More informationHighlights of the Omnibus HIPAA/HITECH Final Rule
Highlights of the Omnibus HIPAA/HITECH Final Rule Health Law Whitepaper Katherine M. Layman 215.665.2746 klayman@cozen.com Gregory M. Fliszar 215.665.7276 gfliszar@cozen.com Judy Wang Mayer 215.665.4737
More informationHIPAA Information. Who does HIPAA apply to? What are Sync.com s responsibilities? What is a Business Associate?
HIPAA Information Who does HIPAA apply to? HIPAA applies to all Covered Entities (entities that collect, access, use and/or disclose Protected Health Data (PHI) and are subject to HIPAA regulations). What
More informationAuditing for HIPAA Compliance: Evaluating security and privacy compliance in an organization that provides health insurance benefits to employees
Auditing for HIPAA Compliance: Evaluating security and privacy compliance in an organization that provides health insurance benefits to employees San Antonio IIA: I HEART AUDIT CONFERENCE February 24,
More informationHIPAA & The Medical Practice
HIPAA & The Medical Practice Requirements for Privacy, Security and Breach Notification Gina L. Campanella, JD, MHA, CHA Founder & Principal, Campanella Law Office Of Counsel, The Beinhaker Law Firm BEINHAKER,
More informationMarch 1. HIPAA Privacy Policy
March 1 HIPAA Privacy Policy 2016 1 PRIVACY POLICY STATEMENT Purpose: The following privacy policy is adopted by the Florida College System Risk Management Consortium (FCSRMC) Health Program and its member
More informationPATTERSON MEDICAL SUPPLY, INC. HIPAA BUSINESS ASSOCIATE AGREEMENT WITH CUSTOMERS
PATTERSON MEDICAL SUPPLY, INC. HIPAA BUSINESS ASSOCIATE AGREEMENT WITH CUSTOMERS This HIPAA Business Associate Agreement ( BA Agreement ), effective as of the last date written on the signature page attached
More informationHIPAA PRIVACY AND SECURITY RULES APPLY TO YOU! ARE YOU COMPLYING? RHODE ISLAND INTERLOCAL TRUST LINN F. FREEDMAN, ESQ. JANUARY 29, 2015.
HIPAA PRIVACY AND SECURITY RULES APPLY TO YOU! ARE YOU COMPLYING? RHODE ISLAND INTERLOCAL TRUST LINN F. FREEDMAN, ESQ. JANUARY 29, 2015. PURPOSE OF PRESENTATION To Discuss Laws Governing Use and Disclosure
More informationHITECH and HIPAA: Highlights for Health Departments. Aimee Wall UNC School of Government
HITECH and HIPAA: Highlights for Health Departments Aimee Wall UNC School of Government When Congress enacted sweeping legislation in February designed to stimulate the nation s economy, it incorporated
More informationIndustry leading Education. Certified Partner Program. Please ask questions Todays slides are available group.
Industry leading Education Certified Partner Program Please ask questions Todays slides are available http://compliancy- group.com/slides023/ Past webinars and recordings http://compliancy- group.com/webinar/
More informationBreach Policy. Applicable Standards from the HITRUST Common Security Framework. Applicable Standards from the HIPAA Security Rule
Breach Policy To provide guidance for breach notification when impressive or unauthorized access, acquisition, use and/or disclosure of the ephi occurs. Breach notification will be carried out in compliance
More informationNew HIPAA Breach Rules NAHU presents the WHAT and WHYs. Agenda
New HIPAA Breach Rules NAHU presents the WHAT and WHYs Presenters: David Smith JD, Vice President, Ebenconcepts Tom Jacobs JD, co-ceo eflexgroup Moderator: Ric Joyner CEBS CFCI, co-ceo, eflexgroup 1 Agenda
More informationLong-Awaited HITECH Final Rule: Addressing the Impact on Operations of Covered Entities and Business Associates
Long-Awaited HITECH Final Rule: Addressing the Impact on Operations of Covered Entities and Business Associates March 7, 2013 Brad M. Rostolsky Partner Reed Smith LLP brostolsky@reedsmith.com Nancy E.
More informationARRA s Amendments to HIPAA Privacy & Security Rules
ARRA s Amendments to HIPAA Privacy & Security Rules Georgina L. O Hara Jessica R. Bernanke April 29, 2009 www.morganlewis.com Amended HIPAA Privacy and Security Rules HIPAA Amendments are in The Health
More informationHIPAA and Lawyers: Your stakes have just been raised
HIPAA and Lawyers: Your stakes have just been raised October 16, 2013 Presented by: Harry Nelson e: hnelson@fentonnelson.com Claire Marblestone e: cmarblestone@fentonnelson.com AGENDA Statutory & Regulatory
More informationHIPAA, Privacy, and Security Oh My!
2014 CliftonLarsonAllen LLP HIPAA, Privacy, and Security Oh My! Chad D. Kunze CPA Health Care Principal Phoenix, AZ CLAconnect.com Learning Objectives At the end of this learning session, you will be able
More informationACC Compliance and Ethics Committee Presentation February 19, 2013
ACC Compliance and Ethics Committee Presentation February 19, 2013 Melinda G. Murray Associate General Counsel, Holy Cross Hospital and Jill M. Girardeau Partner, Womble Carlyle Sandridge & Rice, LLP HIPAA
More informationHIPAA Breach Notification Case Studies on What to Do and When to Report
HIPAA Breach Notification Case Studies on What to Do and When to Report AHLA Physicians and Physician Organizations and Hospitals and Health Systems Law Institute February 9 and10, 2012 Colleen M. McClorey,
More informationH 7789 S T A T E O F R H O D E I S L A N D
======== LC001 ======== 01 -- H S T A T E O F R H O D E I S L A N D IN GENERAL ASSEMBLY JANUARY SESSION, A.D. 01 A N A C T RELATING TO INSURANCE - INSURANCE DATA SECURITY ACT Introduced By: Representatives
More informationAssessing and Mitigating Risk Under the HIPAA Omnibus Rule
Compliance Institute San Diego, CA April 1, 2014 Assessing and Mitigating Risk Under the HIPAA Omnibus Rule Darrell W. Contreras, Esq., LHRM, CHPC, CHC, CHRC Chief Legal & Compliance Officer PlusDelta
More informationAssessing and Mitigating Risk Under the HIPAA Omnibus Rule
Compliance Institute San Diego, CA April 1, 2014 Assessing and Mitigating Risk Under the HIPAA Omnibus Rule Darrell W. Contreras, Esq., LHRM, CHPC, CHC, CHRC Chief Legal & Compliance Officer PlusDelta
More informationThe American Recovery Reinvestment Act. and Health Care Reform Puzzle
The American Recovery Reinvestment Act and Health Care Reform Puzzle Carolyn Heyman-Layne Alaska HCCA Conference March 1, 2012 Comparison of Breach Notification Provisions in the HITECH Act 1 and the Alaska
More informationMEMORANDUM. Health Care Information Privacy The HIPAA Regulations What Has Changed and What You Need to Know
1801 California Street Suite 4900 Denver, CO 80202 303-830-1776 Facsimile 303-894-9239 MEMORANDUM To: Adam Finkel, Assistant Director, Government Relations, NCRA From: Mel Gates Date: December 23, 2013
More information8/30/2016 HIPAA: WHAT S CHANGED?
104 HIPAA: WHAT S CHANGED? Marcia Brauchler, MPH, FACMPE CPC, CPC-H, CPC-I, CPHQ AOA September 7, 2016 9:00 10:00 a.m. All Rights Reserved. 1 TODAY S SESSION 1. A quick recap of HIPAA: then to now 2. Self-Assessment:
More informationHIPAA Basic Training for Health & Welfare Plan Administrators
2010 Human Resources Seminar HIPAA Basic Training for Health & Welfare Plan Administrators Norbert F. Kugele What We re going to Cover Important basic concepts Who needs to worry about HIPAA? Complying
More informationInterim Date: July 21, 2015 Revised: July 1, 2015
HIPAA/HITECH Page 1 of 7 Effective Date: September 23, 2009 Interim Date: July 21, 2015 Revised: July 1, 2015 Approved by: James E. K. Hildreth, Ph.D., M.D. President and Chief Executive Officer Subject:
More informationTexas Health and Safety Code, Chapter 181 Medical Records Privacy Law, HB 300
Texas Health and Safety Code, Chapter 181 Medical Records Privacy Law, HB 300 Training Module provided as a component of the Stericycle HIPAA Compliance Program Goals for Training Understand how Texas
More informationCompliance Steps for the Final HIPAA Rule
Brought to you by The Alpha Group 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 informationThe Privacy Rule. Health insurance Portability & Accountability Act
The Privacy Rule Health insurance Portability & Accountability Act Enacted on August 21, 1996 to amend the Internal Revenue Code of 1986 To improve portability and continuity of health insurance coverage
More informationJOTFORM HIPAA BUSINESS ASSOCIATE AGREEMENT
JOTFORM HIPAA BUSINESS ASSOCIATE AGREEMENT This HIPAA Business Associate Agreement ( HIPAA BAA ) is made between JotForm, Inc., ( JotForm ) and {YourCompanyName} ( Covered Entity or Customer ) as an agreement
More informationAMA Practice Management Center, What you need to know about the new health privacy and security requirements
1. HIPAA Security Rule Johns, Merida L., Information Security, in Johns, Merida L. (ed.) Health Information Management Technology, an Applied Approach, AHIMA: Chicago, IL, 2nd ed. 2007, chapter 19, pp.
More informationTrue or False? HIPAA Update: Avoiding Penalties. Preliminaries. Kim C. Stanger IHCA (7/15)
Protected Health Info HIPAA Update: Avoiding Penalties IHCA (7/15) Preliminaries This presentation is similar to any other legal education materials designed to provide general information on pertinent
More informationHIPAA Compliance for Business Associates ISBA Health Law Symposium October 10, 2017
HIPAA Compliance for Business Associates ISBA Health Law Symposium October 10, 2017 Presenters: Isaac M. Willett & Doriann H. Cain Business Associates & HIPAA in 2017 Increasing focus on business associates
More informationHIPAA OMNIBUS FINAL RULE
HIPAA OMNIBUS FINAL RULE Webinar Series Part 3 Breach Notification April 16, 2013 I. BACKGROUND 2 1 Background > HIPAA Omnibus Final Rule: Announced on January 17, 2013 Published in Federal Register on
More informationTo Notify Or Not To Notify Is No Longer The Question Robin Campbell Chandra Westergaard
SECURITY BREACH RESPONSE To Notify Or Not To Notify Is No Longer The Question Robin Campbell Chandra Westergaard States With Notification Laws Alaska Arizona Arkansas California Colorado Connecticut Delaware
More informationNOTIFICATION OF PRIVACY AND SECURITY BREACHES
NOTIFICATION OF PRIVACY AND SECURITY BREACHES Overview The UT Health Science Center at San Antonio (Health Science Center) is required to report all breaches of protected health information and personally
More informationRISK TRACK. Privacy and Data Protection
RISK TRACK Privacy and Data Protection Presenters Marti Arvin Chief Compliance Officer UCLA Health Sciences Phone: 310-794-6763 MArvin@mednet.ucla.edu Marti Arvin is the Chief Compliance Officer for UCLA
More informationSixth Annual Benchmark Study on Privacy & Security of Healthcare Data
Sixth Annual Benchmark Study on Privacy & Security of Healthcare Data Sponsored by ID Experts Independently conducted by Ponemon Institute LLC Publication Date: May 2016 Ponemon Institute Research Report
More informationHow to mitigate risks, liabilities and costs of data breach of health information by third parties
How to mitigate risks, liabilities and costs of data breach of health information by third parties April 17, 2012 ID Experts Webinar www.idexpertscorp.com Rick Kam President and Co-Founder richard.kam@idexpertscorp.com
More informationHIPAA The Health Insurance Portability and Accountability Act of 1996
HIPAA The Health Insurance Portability and Accountability Act of 1996 Results Physiotherapy s policy regarding privacy and security of protected health information (PHI) is a reflection of our commitment
More informationThe HIPAA Omnibus Rule and the Enhanced Civil Fine and Criminal Penalty Regime
HIPAA BUSINESS ASSOCIATE AGREEMENT BEST PRACTICES: UPDATE 2015 February 20, 2015 I. Executive Summary HIPAA is a federal law passed by Congress to protect medical patient data privacy from misuse or disclosure
More informationBREACH NOTIFICATION POLICY
PRIVACY 2.0 BREACH NOTIFICATION POLICY Scope: All subsidiaries of Universal Health Services, Inc., including facilities and UHS of Delaware Inc. (collectively, UHS ), including UHS covered entities ( Facilities
More informationHIPAA Omnibus Final Rule and Research
Office of the Secretary Office for Civil Rights () HIPAA Omnibus Final Rule and Research Federal Demonstration Partnership September 17, 2013 Christina Heide, JD Senior Health Information Privacy Policy
More informationBUSINESS ASSOCIATE AGREEMENT
BUSINESS ASSOCIATE AGREEMENT This Business Associate Agreement ( Agreement ) by and between (hereinafter known as Covered Entity ) and Office Ally, Inc., a clearinghouse Covered Entity under HIPAA, providing
More informationEffective Date: 4/3/17
HIPAA AND HITECH ADM 067.4 Attachment D Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule and Security Rule Health Information Technology for Economic and Clinical Health (HITECH)
More informationPrivacy Rule Primer. 45 CFR Part 160 and Subparts A and E of Part CFR , 45 CFR CFR
Resource provided by Page 1 of 10 Contents I. The Privacy Rule The Fundamental HIPAA Rule... 1 II. Privacy Rule Overview... 1 III. Privacy Rule Standards and Implementation Specifications Covered in Section
More informationUNDERSTANDING HIPAA & THE HITECH ACT. Heather Deixler, Esq. Associate, Morgan, Lewis & Bockius LLP
UNDERSTANDING HIPAA & THE HITECH ACT Heather Deixler, Esq. Associate, Morgan, Lewis & Bockius LLP 1 Objectives of Presentation Learn what HIPAA is Learn the purpose of HIPAA Understand who HIPAA regulates
More informationREF STANDARD PROVISIONS
This Data Protection Addendum ( Addendum ) is an add- on to the Purchasing Terms and Conditions. It is applicable only in those situations where the Selected Firm/Vendor provides goods or services under
More informationSUBCONTRACTOR BUSINESS ASSOCIATE AGREEMENT
SUBCONTRACTOR BUSINESS ASSOCIATE AGREEMENT (Revised on March 1, 2016) THIS HIPAA SUBCONTRACTOR BUSINESS ASSOCIATE AGREEMENT (the BAA ) is entered into on (the Effective Date ), by and between ( EMR ),
More information2. HIPAA was introduced in There are many facets to the law. Which includes the facets of HIPAA that have been implemented?
Chapter 9 Review Questions 1. What does Administrative Simplification include? Please mark all that apply. a. Privacy rule b. Code sets c. Security rule d. Electronic Transactions e. Identifiers f. Total
More informationLong-Awaited HITECH Final Rule: Addressing the Impact on Operations of Covered Entities and Business Associates
Long-Awaited HITECH Final Rule: Addressing the Impact on Operations of Covered Entities and Business Associates November 7, 2013 Brad M. Rostolsky Partner Reed Smith LLP brostolsky@reedsmith.com Nancy
More informationHIPAA BUSINESS ASSOCIATE AGREEMENT BUSINESS ASSOCIATES AND SUBCONTRACTORS
HIPAA BUSINESS ASSOCIATE AGREEMENT BUSINESS ASSOCIATES AND SUBCONTRACTORS This HIPAA Business Associate Agreement ( BAA ) is entered into on this day of, 20 ( Effective Date ), by and between Allscripts
More informationFuture of Healthcare in Washington April 2, Christiansen IT Law
An Ounce (or More) of Prevention: Getting Ready for OCR Breach Notification and Regulatory Investigations. Future of Healthcare in Washington April 2, 2014 Presenter CV John R. Christiansen, J.D. - Christiansen
More information"HIPAA FOR LAW FIRMS" WHAT EVERY LAW FIRM NEEDS TO KNOW ABOUT HIPAA
"HIPAA FOR LAW FIRMS" WHAT EVERY LAW FIRM NEEDS TO KNOW ABOUT HIPAA Jeanne M. Born, RN, JD SOUTH CAROLINA ASSOCIATION OF LEGAL ADMINISTRATORS THURSDAY, APRIL 14, 2016 Jborn@nexsenpruet.com What Every Law
More informationRIGHT TO ACCESS AND SECURITY RISK ANALYSIS. K a t h r y n A y e r s W i c k e n h a u s e r, M B A, C H P C, C H T S
RIGHT TO ACCESS AND K a t h r y n A y e r s W i c k e n h a u s e r, M B A, C H P C, C H T S RIGHT TO ACCESS WHAT WE LL COVER HHS FAQ Overview Authorization vs Right to Access Record Formats & Delivery
More information