Health Information Management

HIPAA Q&A: Disclosure of breaches

HIPAA Weekly Advisor, April 12, 2010

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Q. Do HITECH notification requirements apply if a workforce member not authorized to use or disclose PHI breaches secured PHI?

A. No notification requirement exists with respect to secured PHI. The Office of the National Coordinator for Health Information Technology published a draft definition of “secure” but not a final definition. This means covered entities and business associates must refer to the National Institute of Standards and Technology (NIST) definition if the interim final rule is effective before HHS publishes a final definition.

At this time, ePHI is considered secure if it is encrypted at an appropriate level; paper PHI is secure if it is properly shredded.

Disciplinary action would be in order, however, to comply with the sanction requirements of the HIPAA privacy and security rules.

Editor’s note: Chris Apgar, CISSP, answered this question. This is not legal advice. Consult your attorney regarding legal matters. Apgar is president of Apgar & Associates, LLC, in Portland, OR. He has more than 17 years of experience in IT and specializes in security compliance, assessments, training, and strategic planning.

 



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