HIPAA Q&A: You’ve got questions. We’ve got answers!
HIM-HIPAA Insider, November 30, 2015
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Submit your HIPAA questions to Associate Editor Nicole Votta at nvotta@hcpro.com and we will work with our experts to provide you with the information you need.
Q: What activity must be audited to comply with the requirement to audit EMR activity? Every action a user takes within a record? Length of time in a record? Or only that the record was accessed and by whom?
A: EMR or EHR audit logs should record who accessed the record, when they accessed the record, and what they did (e.g., add, change, delete, view). It's also a good idea to make sure the amount of time spent looking at the record is recorded. For example, if there is a question why an employee looked at a medical record in the EMR because it appears access wasn't related to the employee's job, recording the time spent looking at the record can differentiate between someone snooping in the record versus someone who accessed the record inadvertently. If the employee spent five or 10 minutes viewing the record versus less than a minute, it could be determined that the employee did more than access the record inadvertently.
Editor’s note: Chris Apgar, CISSP, president of Apgar & Associates, LLC, in Portland, Ore., answered this question for HCPro’s Briefings on HIPAA newsletter. This information does not constitute legal advice. Consult legal counsel for answers to specific privacy and security questions.
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