Health Information Management

Tips on internal sanctions policy

HIPAA Weekly Advisor, December 28, 2009

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HCPro, Inc., hosted an audio conference, “HIPAA Internal Sanctions: Adapt Your Policy to Comply with the HITECH Act,” Thursday, December 3. Each speaker shares a tip on forming your internal sanctions policy:

Nancy Davis, privacy/security officer, Ministry Health Care, Sturgeon Bay, WI: I would stress that the development of written guidance to address the severity of the incident and the appropriate sanction level goes a long way in promoting consistency when applying HIPAA sanctions to all members of the work force.

Dena Boggan, CPC, CMC, CCP, HIPAA privacy/security officer, St. Dominic Jackson Memorial Hospital, Jackson, MS: Be ever-vigilant in watching for new developments in the year to come; and be flexible when revising existing policies and procedures so that you not only meet the obligations of the current language revisions, but you are also able to quickly address any additional additions, deletions, or changes to your policies to comply with these ever-changing regulations.

Editor’s note: The audio conference is now available for purchase on CD-ROM or audio on-demand by going here. For more information on HCPro, Inc.’s HIPAA compliance products, go to our Health Information Management page.



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