| HIPAA compliance requires special focus
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| | statement of least privilege data access
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| and effort as failure to comply carries
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| | to complete the job, definition of PHI
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| significant risk of damage and penalties.
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| | and incident monitoring and reporting
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| A practice with multiple separate
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| | procedures. Educational materials may
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| systems for patient scheduling,
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| | include case studies, control questions,
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| electronic medical records, and billing,
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| | and a schedule of review seminars for
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| requires multiple separate HIPAA
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| | personnel.Technology Requirements for
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| management efforts. This article
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| | HIPAA Compliance Technology
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| presents an integrated approach to HIPAA
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| | implementation of HIPAA proceeds in
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| compliance and outlines key HIPAA
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| | stages from logical data definition to
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| terminology, principles, and requirements
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| | physical data center to network. To
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| to help the practice owner to ensure
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| | assure physical data center security, the
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| HIPAA compliance by medical billing
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| | manager must
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| service and software vendors.The last
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| | Lock data center
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| decade of the previous century witnessed
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| | Manage access list
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| accelerating proliferation of digital
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| | Track data center access with closed
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| technology in health care, which, along
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| | circuit TV cameras to monitor both
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| with reduced costs and greater service
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| | internal and external building activities
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| quality, introduced new and greater risks
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| | Protect access to data center with 24 x
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| for accidental disclosure of personal
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| | 7 onsite security
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| health information.The Health insurance
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| | Protect backup data
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| Portability and Accountability Act
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| | Test recovery procedure
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| (HIPAA) was passed in 1996 by Congress to
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| |
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| establish national standards for privacy
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| | For network security, the data center
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| and security of personal health data.
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| | must have special facilities for
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| The Privacy Rule, written by the US
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| | Secure networking - firewall protection,
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| Department of Health and Human Services
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| | encrypted data transfer only
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| took effect on April 14, 2003.Failure to
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| | Network access monitoring and report
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| comply with HIPAA risks accreditation and
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| | auditing
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| reputation damage, lawsuits by federal
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| government, financial penalties, ranging
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| | For data security, the manager must
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| from $100 to $250,000, and imprisonment,
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| | have
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| ranging from one year to ten years.
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| | Individual authentication - individual
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| Protected Health Information (PHI) The
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| | logins and passwords
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| key term of HIPAA is Protected Health
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| | Role Based Access Control (see below)
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| Information (PHI), which includes
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| | Audit trails - all access to all data
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| anything that can be used to identify an
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| | fields tracked and recorded
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| individual and any information shared
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| | Data discipline - Limited ability to
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| with other health care providers or
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| | download data
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| clearinghouses in any media (digital,
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| verbal, recorded voice, faxed, printed,
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| | Role Based Access Control (RBAC) RBAC
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| or written). Information that can be
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| | improves convenience and flexibility of
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| used to identify an individual includes:
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| | systems management. Greater convenience
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|
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| | helps reducing the errors of commission
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| Name
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| | and omission in granting access
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| Dates (except year)
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| | privileges to users. Greater flexibility
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| Zip code of more than 3 digits,
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| | helps implement the policy of least
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| telephone and fax numbers, email
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| | privilege, where the users are granted
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| Social security numbers
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| | only as much privileges as required for
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| Medical record numbers
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| | completing their job.RBAC promotes
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| Health plan numbers
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| | economies of scale, because the frequency
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| License numbers
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| | of changes of role definition for a
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| Photographs Information shared with
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| | single user is higher than the frequency
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| other healthcare providers or
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| | of changes of role definitions across
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| clearinghouses
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| | entire organization. Thus, to make a
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|
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| | massive change of privileges for a large
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| Nursing and physician notes
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| | number of users with same set of
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| Billing and other treatment records
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| | privileges, the administrator only makes
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| Principles of HIPAA HIPAA intends to
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| | changes to the role
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| allow smooth flow of PHI for healthcare
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| | definition.Hierarchical RBAC further
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| operations subject to patient's consent
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| | promotes economies of scale and reduces
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| but prohibit any flow of unauthorized PHI
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| | the likelihood of errors. It allows
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| for any other purposes. Healthcare
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| | redefining roles by inheriting privileges
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| operations include treatment, payment,
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| | assigned to roles in the higher
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| care quality assessment, competence
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| | hierarchical level.RBAC is based on
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| review training, accreditation, insurance
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| | establishing a set of user profiles or
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| rating, auditing, and legal
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| | roles according to responsibilities.
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| procedures.HIPAA promotes fair
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| | Each role has a predefined set of
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| information practices and requires those
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| | privileges. The user acquires privileges
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| with access to PHI to safeguard it.
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| | by receiving membership in the role or
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| Fair information practices means that a
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| | assignment of a profile by the
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| subject must be allowed
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| | administrator.Every time when the
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|
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| | definition of the role changes along with
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| Access to PHI,
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| | the set of privileges that is required to
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| Correction for errors and completeness,
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| | complete the job associated with the
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| and
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| | role, the administrator needs only to
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| Knowledge of others who use
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| | redefine the privileges of the role. The
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| PHISafeguarding of PHI means that the
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| | privileges of all of the users that have
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| persons that hold PHI must
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| | this role get redefined
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|
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| | automatically.Similarly, if the role of a
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| Be accountable for own use and
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| | single user is changed, the only
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| disclosure
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| | operation that needs to be performed is
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| Have a legal recourse to combat
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| | the reassignment of the user profile,
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| violations HIPAA Implementation Process
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| | which will redefine user's access
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| HIPAA implementation begins upon making
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| | privileges automatically according to the
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| assumptions about PHI disclosure threat
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| | new profile. Summary HIPAA compliance
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| model. The implementation includes both
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| | requires special practice management
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| pre-emptive and retroactive controls and
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| | attention. A practice with multiple
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| involves process, technology, and
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| | separate systems for scheduling,
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| personnel aspects.A threat model helps
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| | electronic medical records, and billing,
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| understanding the purpose of HIPAA
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| | requires multiple separate HIPAA
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| implementation process. It includes
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| | management efforts. An integrated system
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| assumptions about
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| | reduces the complexity of HIPAA
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|
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| | implementation. By outsourcing
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| Threat nature (Accidental disclosure by
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| | technology to a HIPAA-compliant vendor of
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| insiders? Access for profit? ),
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| | vericle-like technology solution on an
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| Source of threat (outsider or insider?),
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| | ASP or SaaS basis, HIPAA management
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|
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| | overhead can be eliminated (see companion
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| Means of potential threat (break in,
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| | papers on ASP and SaaS for medical
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| physical intrusion, computer hack,
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| | billing).Yuval Lirov, PhD, author of
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| virus?),
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| | "Mission Critical Systems Management"
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| Specific kind of data at risk (patient
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| | (Prentice Hall, 1997), inventor of
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| identification, financials, medical?),
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| | multiple patents in artificial
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| and
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| | intelligence and computer security, and
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| Scale (how many patient records
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| | CEO of Billing Technologies. Vericle
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| threatened?). HIPAA process must include
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| | delivers comprehensive practice workflow
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| clearly stated policy, educational
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| | engine that integrates patient
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| materials and events, clear enforcement
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| | scheduling, electronic medical records
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| means, a schedule for testing of HIPAA
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| | (EMR), billing, transcription, and
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| compliance, and means for continued
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| | compliance management. It improves
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| transparency about HIPAA compliance.
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| | billing performance and reduces audit
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| Stated policy typically includes a
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| | risk.
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