![]() Continuing-or making an increased effort-to take advantage of the safe harbor provision by encrypting PHI according to HHS’ guidance and.Determining whether any forms, such as requests for access, should be updated or created.Revising business associate contract templates and beginning the painful process of amending/renegotiating each one. ![]() Training workforce and promoting more ongoing awareness.Amending notices of privacy practices (and making sure the revised notices are properly posted and distributed).Revising breach notification policies, procedures, and breach response plans, particularly with respect to conducting a risk assessment for determining whether notification is required.Revising privacy and security policies and procedures to bring the organization into compliance-this is a good opportunity to review and fine-tune existing policies based on guidance and experience.Performing a gap analysis to determine what policies and procedures must be revisited in light of the Omnibus Rule.In response, covered entities should consider: The Omnibus Rule, in part, expands certain HIPAA obligations to business associates and their subcontractors, modifies the breach notification standard, expands patient rights to access and to restrict disclosure of protected health information (PHI), imposes new rules governing uses and disclosures of PHI, clarifies enforcement approaches, and addresses obligations under the Genetic Information Nondiscrimination Act of 2008 (GINA). ![]() 25, 2013, implements most of the privacy and security provisions of the Health Information Technology for Economic and Clinical Health (HITECH) Act and significantly extends the reach and limits of HIPAA. The Omnibus Rule, which is expected to be published Jan. 17, 2013, the Department of Health and Human Services (HHS) released the long-awaited “ Omnibus Rule,” which amends the administrative simplification provisions of the Health Insurance Portability and Accountability Act (HIPAA).
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