HIPAA Privacy the Morning After - What do we do now?

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Presentation transcript:

HIPAA Privacy the Morning After - What do we do now? Healthcare Privacy Roundtable June 5, 5:00 PM Ross Hallberg Chief Compliance Officer and Chief Privacy Official John Muir / Mt. Diablo Health System

The practical, operational reality is always different from the policy Who actually understood and learned what? Fixing misunderstandings - The hype and perspective problems Communication and resolution of new issues Follow-up training What does all this imply for on-going training? Will all those policies, procedures, and forms we developed actually work? The practical, operational reality is always different from the policy author’s perspective Dealing with new and better ideas on how to do things Evaluating management’s implementation of policies and procedures Did we achieve compliance? If not, then remediation

On Organized Health Care Arrangement and Hybrid Entity Sure glad we did both of these, but did we miss anything? Are there physician issues just waiting to happen? Have we adversely impacted patient care or safety? Somewhere, somehow - seems possible I hope we are vigilant and speedy in identifying and resolving Privacy safeguards and Security regulations Let’s try not to do things over again But it all has to fit together

What are we REALLY going to do about -- Accounting of disclosures Attaching medical record amendments everywhere Longer term procedures - record keeping and documentation - mitigation - dealing with violations - issue resolution - management ownership - BA agreements - policy and procedure ownership and modification HIS application vendor issues NOPP tracking, amendment tracking, accounting of disclosures, no information patients, etc. Did you get any application help on time? We didn’t