Health Information Management

Lessons found in OCR resolution agreements

HIM-HIPAA Insider, June 23, 2014

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by Roger Schindell
It's one of the most common questions privacy and security officers ask, and one I hear frequently myself: "How can I prepare for HIPAA compliance?"
The simplest, but most sincere answer is to always perform a security risk assessment. An organization's policies and procedures must be in order and up to date. More importantly, they must be enforced. This underscores the need to train, train, and train some more. But where do these recommendations come from, and how do we learn about compliance?
One of the most important tools that many covered entities (CE) overlook are OCR resolution agreements. Every time OCR conducts a breach investigation, it posts valuable lessons for CEs on its website.
What makes these resolution agreements such a valuable resource? First, they give us a glimpse into what OCR is thinking. Additionally, they delineate what OCR, the HIPAA oversight agency, deems important when it comes to ensuring (to the extent possible) that a breach will not reoccur. The resolution agreements are readily available online.
Currently, 21 resolution agreements are published on the HHS website. The agreements provide guidance on how to avoid breaches as well as how to avoid being another name on OCR's "wall of shame." Simply put, if your organization experiences a breach, this is where your dirty laundry hangs for everyone to see. See the sidebar for a summary of the data.
Continue reading "Lessons found in OCR resolution agreements" on the HCPro website. Shindell is CEO of Carosh Compliance Solutions, which specializes in HIPAA compliance consulting with small to midsize U.S. companies, wrote this article for Briefings on HIPAA. BOH subscribers have free access to this article in the June issue. Contact Shindell at


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