Breaking down OCR's HIPAA hotspots
HIM-HIPAA Insider, August 22, 2011
The Office for Civil Rights (OCR) has revealed the top areas of interest on its HIPAA privacy and security compliance radar.
Adam Greene, former senior health information technology and privacy advisor at OCR and now partner at the law firm Davis Wright Tremaine in Washington, D.C., recently discussed each hot topic with HealthLeaders Media.
Hotspot: Incident detection and response (OCR’s top issue)
Greene: I recommend both a top-down and bottom-up approach. From the top, covered entities and business associates should evaluate whether they are reasonably logging system activities and reviewing those logs in a way that is reasonably likely to detect impermissible uses and disclosures.
From the bottom, covered entities and business associates should ensure that all staff who have access to PHI are reasonably trained to be able to spot an impermissible use or disclosure and report it to the appropriate person. The HITECH Act makes clear that the entire organization is treated as knowing of a breach if anyone, other than the person who committed the impermissible use or disclosure, knows of the breach.
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