June 21, 2016

7-Step Technology Checklist for PHI Protection

Mark Olschesky
Mark Olschesky

Datica Alumni — Former Chief Data Officer

Criminal and financial penalties alongside severe reputation loss — with wagers so high, hospitals need to grow above the impromptu manual audits. Further contextual proof is given since these audits review a very minute percentage of all daily access events. Ensuring widespread patient privacy requires a solid foundation involving policy, procedures, and technology.

Certain tasks simply cannot be addressed efficiently when done manually. With the appropriate technology, hospitals and healthcare entities can move beyond the limitations of random and manual audits. Now, patient privacy monitoring can be automated.

Automation implementation through technology helps healthcare organizations investigate and track breaches more efficiently as well. Reports on unauthorized access attempts to patient medical records are generated in addition to enacted practices to prevent another breach. Having automated solutions for integrating and correlating access to PHI across various healthcare systems ensures the simplest and most effective way to streamline all processes and procedures that ensure compliance. The OCR HIPAA audits and the HIPAA Omnibus Rule mandate healthcare organizations have live practices that prove a hospital is able to monitor and react to patient records access.

When evaluating technology for a patient privacy-monitoring program, the following checklist can ensure the selected system is capable of critical capabilities:

  1. Key monitoring of all patient records access: By automatically aggregating audit logs from across the entire organization and providing single search queries and proactive auditing
  2. Catching and resolving single as well as recurring breaches in real-time: It is important that inappropriate activity be spotted as it happens by proactively auditing all access to patient records
  3. Documenting breach investigations and their resolution: With a centralized and automated system, information required for documenting all investigation and their resolutions can be easily provided for fulfilling notification requirements
  4. Providing reporting per state and federal guidelines: Helps in the creation of a centralized, comprehensive environment for reviewing documented findings and providing insight into areas that require additional security measures and/ or employee education
  5. Documenting the release of medical records: When releasing medical records, a HIPAA violation can occur in so many ways and it is important that there is a procedure in place to document and track their release
  6. Accounting for disclosures: Hospitals and business associates are required to address all PHI disclosures, and the process must be able to track and document the disclosures in a central repository
  7. Meeting MACRA requirements of patient privacy: Should allow hospitals to implement policies and procedures for preventing, detecting, containing and correcting security violations.

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