Health Information Management

Protecting PHI stored in Microsoft applications

HIM-HIPAA Insider, November 17, 2009

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Q. How should we manage the tracking/logging of PHI that may be stored in standard Microsoft products, such as Outlook® calendars or SharePoint® lists? Our electronic medical record application has built-in PHI audit trails/log reports.
Increasingly, our end users create appointments and lists in standard Microsoft applications. If these lists contain PHI, does a method of tracking these data to assist in monitoring breaches exist? Am I overreacting or should I be concerned about PHI and HIPAA security requirements in such applications?

A. You need to be concerned about protecting PHI wherever it exists in your organization.

The level of PHI that Outlook calendars may include is probably minimal. Employees who meet to discuss something pertaining to a particular patient probably include the patient’s name in the meeting request, but they probably don’t include any additional information.

Other applications, such as Word® or Excel®, may contain greater amounts of PHI, depending on the individual user’s responsibilities.

Tracking or logging PHI in these applications would be very difficult, so limiting access to computers or other devices on which this information is stored is the best approach.

All devices containing PHI should be password- protected at a minimum. Encourage PC users to store their files on network drives rather than their local hard drives to protect data and ensure periodic backup.

Editor’s note: Mary Brandt, president of Brandt & Associates, Inc., a healthcare consulting firm in Bellaire, TX answered this question in the November issue of Briefings on HIPAA.



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