Health Information Management

Get to the bottom of privacy investigations

Briefings on HIPAA, May 1, 2008

Covered entities (CE) that have policies and procedures in place for privacy breach investigations might lack something equally as important: experience implementing these policies and procedures in difficult situations. Emotional circumstances, dishonest employees, and fading memories can sidetrack, or even derail, any investigation. After ensuring that your investigative process is up to date (see p. 3 of the PDF of this issue for a sample HIPAA investigation flowchart), consider your responses to these problems. "Policy is there to take out the human element," says Frank Ruelas, compliance officer and risk manager at Maryvale Hospital in Phoenix.

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