HIPAA Implementation Strategies for Compliance Professionals

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Presentation transcript:

HIPAA Implementation Strategies for Compliance Professionals David J. Butler Christopher E. Coleman presented to: Fifth Annual National Congress on Health Care Compliance February 8, 2001

Health Insurance Portability and Accountability Act of 1996 Compliance Professionals Establish the Context HIPAA Health Insurance Portability and Accountability Act of 1996 Accountability Administrative Simplification Insurance Portability The so-called Administrative Simplification” components of HIPAA are just one piece of the much larger legislation (HIPAA), which was intended to support the portability of existing condition coverage for patients in transition from one employer-based health plan to another. Those insurance provisions were enacted back in 1996 when the legislation was first enacted. When we speak about HIPAA today, we usually mean the EDI and Security/Privacy components. That is, Administrative Simplification. Administrative Simplification is composed of 5 separate proposed rules issued by the DHHS in 1999 which includes Transaction Standards and Code Sets Provider Identifiers Employer Identifiers Security Privacy As of 12/5/00, only the Transaction Standards and Code Sets rule has been finalized Security EDI Privacy Transactions Code Sets Identifiers Copyright 2001 Strategic Management Systems, Inc.

Compliance Professionals Understand Your Role You are Part of a Corporate Project Plan Know and Understand where You Fit Primary Focus of Implementation for Compliance Professionals Privacy Regulations Privacy Rule Policies and Procedures Training Project Coordination Copyright 2001 Strategic Management Systems, Inc.

Compliance Professionals Identify Your Scope of Work Privacy Regulations Require Many Policies and Procedures EDI Security Privacy IT Revision Policies & Procedure Copyright 2001 Strategic Management Systems, Inc.

Compliance Professionals Identify Your Scope of Work Identify all Policies and Procedures Necessary for Your Organizations Assess and Ensure Applicability to Your Organization Leverage Existing Policies and Procedures in Compliance Program Copyright 2001 Strategic Management Systems, Inc.

Compliance Professionals Develop Your Work Plan Develop a Work Plan Drafting and Deploying Policies and Procedures Deploying Training Identifies Scope of Work Accordingly to Deliverables Identify Process for Policy & Procedure Approval Interdepartmental Review Legal Review Executive Committee Review Identifies Timelines What Policies should be Completed before Others When to Conduct Training Copyright 2001 Strategic Management Systems, Inc.

Compliance Professionals Develop Your Work Plan (cont.) Allocates Responsibilities Establish separate Work Groups according to Subject Matter or Business Unit Corporate Level Allows Assessments and Updates Ensure Coordination with Security Copyright 2001 Strategic Management Systems, Inc.

Compliance Professionals Conduct Awareness Training Once Corporate Level Policies and Procedures are Drafted Establish Context All employees understand need for Policies and Procedures Expectations will be Established on Policies to Come for each Department Expectations will be Established on Modifying Culture Consider Both Privacy and Security Awareness Copyright 2001 Strategic Management Systems, Inc.

Compliance Professionals Distribute Policies and Procedures Disseminate Corporate Level Policies and Procedures Applicable Policies to Each Business Unit Procedures Must Be Tailored for Applicability Ensure Business Unit Responsibility Ensure Functional Training Regarding Specific Policies and Procedures Required by Privacy Regulations Copyright 2001 Strategic Management Systems, Inc.

Compliance Professionals Maintain Executive Communication Ensure Adequate Communication to Executive Committee Report on Progress and Challenges Justify Budgetary and Resource Allocations Avoid Surprises Copyright 2001 Strategic Management Systems, Inc.

Compliance Professionals Its Simply Another Regulation HIPAA Administrative Simplification just another section of the C.F.R. Take a Systematic Approach Avoid Getting Overwhelmed Successful Accomplishment Focus on Ultimate Objective Ensure Patient Confidentiality Copyright 2001 Strategic Management Systems, Inc.