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  • Posted in: HIPAA

    Keep in mind that if a CE...and this happens a lot and is written in many BAAs...only requires the BA to notify the CE when a breach occurs as determined by the BA...this creates a number of issues.  A few include: This is inconsistent with ...

  • Posted in: HIPAA

    Thank for your response Frank, that was helpful.  I am showing my newness to this position so appreciate you pointing out my need to clarify the low-level breach verbiage I used.    What I meant was because every incident is viewed as a breach ...

  • Posted in: HIPAA

    Jennifer...here's my feedback.  Let me know if any of it was helpful and certainly let's see what others have to share. Is it the BA's responsibility to report and notify when a breach has occurred? or is that something that is discussed ...

  • Posted in: HIPAA

    I have been updating our internal procedures and have been trying to find out specific information as to the obligations of reporting/notifying and follow up when a breach has happened by the Business Associate (BA).  Is it the BA's responsibility ...

  • Posted in: HIPAA

    Has anyone engaged the Compliance Group's services? If so, would you be willing to share your experiences and impressions of what they offer?  Many thanks. ------------------------------ Freda Driscoll-Sbar, M.Ed. Vice President of Quality ...

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  • As I had a few days off, I have been trying to think of ways to make our compliance/privacy work visible - boards, senior leadership, our own team - while minimizing the effort it takes to do this work. We currently use Microsoft Teams for tasks. ...

  • Thank you all for your responses. ------------------------------ Rachel Anderson, MSN, RN, CHC ------------------------------

  • Personally I don't think that sounds like a compliance function and I wouldn't agree to have compliance take on that responsibility for other departments / non-compliance policies. If there is an exception process for a policy that should be ...

  • A couple thoughts in addition to what has already been shared: 1) Policy exceptions should be documented. I like to have a form for the policy owner to use to document each exception (which can help ensure all the right information is captured, ...

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