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© Clearwater Compliance LLC | All Rights Reserved Copyright Notice 1 Copyright Notice. All materials contained within this document are protected by United States copyright law and may not be reproduced, distributed, transmitted, displayed, published, or broadcast without the prior, express written permission of Clearwater Compliance LLC. You may not alter or remove any copyright or other notice from copies of this content. For reprint permission and information, please direct your inquiry to firstname.lastname@example.org email@example.com
© Clearwater Compliance LLC | All Rights Reserved Legal Disclaimer 2 Legal Disclaimer. This information does not constitute legal advice and is for educational purposes only. This information is based on current federal law and subject to change based on changes in federal law or subsequent interpretative guidance. Since this information is based on federal law, it must be modified to reflect state law where that state law is more stringent than the federal law or other state law exceptions apply. This information is intended to be a general information resource regarding the matters covered, and may not be tailored to your specific circumstance. YOU SHOULD EVALUATE ALL INFORMATION, OPINIONS AND ADVICE PROVIDED HEREIN IN CONSULTATION WITH YOUR LEGAL OR OTHER ADVISOR, AS APPROPRIATE. The existence of a link or organizational reference in any of the following materials should not be assumed as an endorsement by Clearwater Compliance LLC.
© Clearwater Compliance LLC | All Rights Reserved HIPAA Compliance BootCamp™ Wrap Up Bob Chaput 615-656-4299 or 800-704-3394 bob.chaput@ClearwaterCompliance.com Clearwater Compliance LLC 3
© Clearwater Compliance LLC | All Rights Reserved 4 Gregory J. Ehardt, JD, LL.M. HIPAA/Assistant Compliance Officer - HCA Adjunct Professor Office of General Counsel Idaho State University Bob Chaput, CISSP, CIPP/US CHP, CHSS CEO Clearwater Compliance Expert Instructors Elizabeth Warren, Esq. Partner Bass, Berry & Sims, PLC Mary Chaput, MBA, HCISPP, CIPP/US, CHP CFO & Chief Compliance Officer Clearwater Compliance Meredith Phillips, MHSA, CHC, CHPC Chief Information Privacy & Security Officer Henry Ford Health System David Finn, CISA, CISM, CRISC Health IT Officer Symantec Corporation
© Clearwater Compliance LLC | All Rights Reserved 30 Day Access, from today! Clearwater Expert Email | Phone | GoToMeeting All Clearwater HIPAA Compliance BootCamp™ Attendees 5 Clearwater HIPAA Mentor™ Contact: Bob Chaput – Bob.Chaput@ClearwaterCompliance.com Bob.Chaput@ClearwaterCompliance.com – I’ll assist you or connect you with an Expert
© Clearwater Compliance LLC | All Rights Reserved Our Overarching Mission 6 1.Complaint 2.Breach Notice 3.SAG HITECH Action 4.FTC Action 5.Whistleblower 6.State Action (e.g., DHCS) 7.OCR Audit http://www.hhs.gov/ocr/privacy/hipaa/enforcement/process/index.html Avoid the following…
© Clearwater Compliance LLC | All Rights Reserved Policy defines an organization’s values & expected behaviors; establishes “good faith” intent People must include talented privacy & security & technical staff, engaged and supportive management and trained/aware colleagues following PnPs. Procedures or processes – documented - provide the actions required to deliver on organization’s values. Safeguards includes the various families of administrative, physical or technical security controls ( including “guards, guns, and gates”, encryption, firewalls, anti-malware, intrusion detection, incident management tools, etc.) Balanced Compliance Program Four Critical Dimensions Clearwater Compliance Compass™ 7
© Clearwater Compliance LLC | All Rights Reserved 9 Actions to Take Now 8 4.Complete a HIPAA Security Risk Analysis (45 CFR §164.308(a)(1)(ii)(A)) 5.Complete a HIPAA Security Evaluation (= compliance assessment) (45 CFR § 164.308(a)(8)) 6.Complete Technical Testing of Your Environment (45 CFR § 164.308(a)(8)) 7.Implement a Strong, Proactive Business Associate / Management Program (45 CFR §164.502(e) and 45 CFR §164.308(b)) 8.Complete Privacy Rule and Breach Rule compliance assessments (45 CFR §164.530 and 45 CFR §164.400) 9.Document and act upon a remediation plan 1.Set Privacy and Security Risk Management & Governance Program in place (45 CFR § 164.308(a)(1)) 2.Develop & Implement comprehensive HIPAA Privacy and Security and Breach Notification Policies & Procedures (45 CFR §164.530 and 45 CFR §164.316) 3.Train all Members of Your Workforce (45 CFR §164.530(b) and 45 CFR §164.308(a)(5)) Demonstrate Good Faith Effort!
© Clearwater Compliance LLC | All Rights Reserved What is Your Organization’s Vision? 9 Marketing, Customer Service & Patient Safety Strategy HIPAA-HITECH Compliance Project Patient/Member Privacy & Security Program
© Clearwater Compliance LLC | All Rights Reserved Accretive Share Price & Story 10 July 2011 - Accretive employee’s laptop computer, containing 20 million pieces of information on 23,000 patients, was stolen from the passenger compartment of the employee’s car 7/31/2012 $2.5M MN SAG Settlement 1/19/2012 MN SAG Suit 12/31/2013 FTC Settle. 6/13/2013 Class Action Suit 03/14/2014 De-Listed NYSE 4/2/2013 CEO Replaced 8/26/2013 CFO Replaced 9/27/2013 $14M Class Settlement 01/2014 170 Job Cuts 4/13/2013 COO Replaced
© Clearwater Compliance LLC | All Rights Reserved Supplemental Materials 10-1.HIPAA Privacy Rule Requirements for Business Associates 10-2.HIPAA Security Rule Requirements for Business Associates FINAL 10-3.Special HIPAA Requirements for Group Health Plans and their Sponsors 10-4.Risky Business: How to Conduct a Bona Fide HIPAA Risk Analysis 10-5.HIPAA Compliance | Now Even More Critical for Third Party Administrators 10-6.HIPAA Compliance | Now Even More Critical for Managed Care Organizations 11
© Clearwater Compliance LLC | All Rights Reserved Copyright Notice 1 Copyright Notice. All materials contained within this document are protected by United.
© Clearwater Compliance LLC | All Rights Reserved Copyright Notice Copyright Notice. All materials contained within this document are protected by United.
© Clearwater Compliance LLC | All Rights Reserved Copyright Notice 1 Copyright Notice. All materials contained within this document are protected.
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.
PHASE II OF HIPAA AUDIT PROGRAM June 2016 Presented by John P. Murdoch II, Esq. of Wilentz, Goldman & Spitzer, P.A. Two Industrial Way West Two Industrial.
HIPAA PRIVACY AND SECURITY AWARENESS. Introduction The Health Insurance Portability and Accountability Act (known as HIPAA) was enacted by Congress in.
1 PARCC Data Privacy & Security Policy December 2013.
HIPAA: FEDERAL REGULATIONS REGARDING PATIENT SECURITY.
COMPLYING WITH HIPAA BUSINESS ASSOCIATE REQUIREMENTS Quick, Cost Effective Solutions for HIPAA Compliance: Business Associate Agreements.
Where to start Ben Burton, JD, MBA, RHIA, CHP, CHC.
Steps to Compliance: Risk Assessment PRESENTED BY.
THE DEPARTMENT OF HEALTH AND HUMAN SERVICES (HHS) OFFICE FOR CIVIL RIGHTS (OCR) ENFORCES THE HIPAA PRIVACY, SECURITY, AND BREACH NOTIFICATION RULES HIPAA.
HIPAA Security Presentation to The American Hospital Association Dianne Faup Office of HIPAA Standards November 5, 2003.
COMPLYING WITH HIPAA PRIVACY RULES Presented by: Larry Grudzien, Attorney at Law.
HIPAA Privacy Training. 2 HIPAA Background Health Insurance Portability and Accountability Act of 1996 Copyright 2010 MHM Resources LLC.
HIPAA: So You Think You’re Compliant September 1, 2011 Carolyn Heyman-Layne, J.D.
Data Security & Privacy: Fundamental Risk Mitigation Tactics 360° of IT Compliance Anthony Perkins, Shareholder Business Law Practice Group Data Security.
National Health Information Privacy and Security Week Understanding the HIPAA Privacy and Security Rule.
LAW SEMINARS INTERNATIONAL CLOUD COMPUTING: LAW, RISKS AND OPPORTUNITIES Developing Effective Strategies for Compliance With the HITECH Act and HIPAA’s.
DEED WorkForce Center Reception and Resource Area Certification Program Module 2 Unit 1b: WorkForce Center System II Learning Objectives III.
Policies for Information Sharing April 10, 2006 Mark Frisse, MD, MBA, MSc Marcy Wilder, JD Janlori Goldman, JD Joseph Heyman, MD.
Topics Rule Changes Skagit County, WA HIPAA Magic Bullet HIPAA Culture of Compliance Foundation to HIPAA Privacy and Security Compliance Security Officer.
HIPAA Basic Training for Privacy and Information Security Vanderbilt University Medical Center VUMC HIPAA Website: HIPAA Basic.
Rhonda Anderson, RHIA, President …is a PROCESS, not a PROJECT 2.
HIPAA COMPLIANCE IN YOUR PRACTICE MARIBEL VALENTIN, ESQUIRE.
Disclaimer This presentation is intended only for use by Tulane University faculty, staff, and students. No copy or use of this presentation should occur.
Chris Apgar, CISSP President, Apgar & Associates, LLC December 12, 2007.
HIPAA Privacy Rules: What Are Plan Sponsors Required to Do?
FleetBoston Financial HIPAA Privacy Compliance Agnes Bundy Scanlan Managing Director and Chief Privacy Officer FleetBoston Financial.
Privacy and Security Laws for Health Care Organizations Presented by Robert J. Scott Scott & Scott, LLP
LeToia Crozier, Esq., CHC Vice President, Compliance & Regulatory Affairs Corey Wilson Director of Technical Services & Security Officer Interactive Think.
Dealing with Business Associates Business Associates Business Associates are persons or organizations that on behalf of a covered entity: –Perform any.
1. As a Florida KidCare community partner families entrust you to not only help them navigate the Florida KidCare system but to keep the information they.
CONFIDENTIAL © 2014 Barnes & Thornburg LLP. All Rights Reserved. This page, and all information on it, is confidential, proprietary and the property of.
What Advising Administrators Need To Know about Legal Issues NACADA Executive Office Kansas State University 2323 Anderson Ave, Suite 225 Manhattan, KS.
An Introduction to Compliance and HIPAA Privacy RVHIMA Spring 2016 Meeting Joshua A. Lenavitt, MHA Regional Director of Compliance and Privacy Baptist.
Notice of Privacy Practices Nebraska SNIP Privacy Subgroup July 18, 2002 Michael J. Brown, MHA, CPA Vice-President, Administrative & Regulatory Affairs,
March 19, 2009 Changes to HIPAA Privacy and Security Requirements Joel T. Kopperud Scott A. Sinder Rhonda M. Bolton.
NYSAIS | Webinar | May 11, 2011 Electronic Signatures and Red Flag Rules Presented by: Donald J. Mosher Partner Schulte Roth & Zabel LLP
Investigating & Preserving Evidence in Data Security Incidents Robert J. Scott Scott & Scott, LLP
Mesa Mental Health HIPAA Summit West, June 5, HIPAA Compliance Case Study: Practical HIPAA Compliance Strategies for Small Providers Session 2.07;
Dino Tsibouris & Mehmet Munur Privacy and Information Security Laws and Updates.
Jill Moore April 2013 HIPAA Update: New Rules, New Challenges.
℠ Pryvos ℠ Computer Security and Forensic Services May 27, 2015 Copyright © 2015 Pryvos, Inc. 1.
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