HIPAA
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| healthcare provider that chooses to transmit health info electronically, a health plan, or healthcare clearinghouse, and must comply w/HIPAA's requirements | covered entity
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| claims/encounter info, eligibility requests, referrals & authorizations, & claims status inquiries are the 4 types medical info a health care provider can submit electronically/on-paper & are required to | transmit using HIPPA's standards
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| health plan & healthcare clearinghouse must be able to receive the provider's 4 types medical info subject to HIPAA standards, but also be able to electronically conduct | premium payments, claim payments, & remittance advice, enrollment & disenrollment, & coordination of benefits
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| healthcare clearinghouse working on behalf of healthcare provider, in role of business associate, must also | comply w/HIPAA standards requirements under a "covered entity"
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| electronic exchange of info between (2) covered-entity business partners using HIPAA-defined electronic data interface exchange transaction standards for the exchange | covered transactions
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| patient sending email message to physician containing patient-identifiable info ___ be considered a covered transaction under HIPAA | would not
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| physician transmitting electronic claim to health care plan or referral/auth. electronically to another physician, lab or hospital ___ be considered a covered transaction under HIPAA | would
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| the receipt of a physician transmitting electronic claim to health care plan or referral/auth. electronically to another physician, lab or hospital | invokes security protections the physician must have in place under HIPAA
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| computer-to-computer exchange of routine business info using publicly available standards | electronic data interchange (EDI)
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| refers to transmission of info between 2 parties to carry out financial/administrative activities | transaction
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| HIPAA requires that providers carefully define who has access to personal health information; what portions of PR available to front-office, utilization mgrs, billing personnel, etc. | minimum necessary
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| discourage anyone from having open access to medical records that contain files of info regarding an individual's medical history | intent of minimum necessary
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| legal document developed by a practice & its attorney stating what practice will do to protect each patient's rights | Notice of Privacy Practices (NPP)
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| one person who oversees privacy activities & security protections; can delegate responsibilities to privacy team but alone holds accountability for HIPAA compliance | privacy & security officials
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| under HIPAA's privacy & security officials, members of a privacy team must be | trained specifically to fulfill any delegated responsibilities
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| the privacy & security official may be | the same person
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| in larger practices, depending on the workload, the privacy & security official would usually be | separate people
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| info that can be used to identify an individual because it contains 1/more patient identifiers | Protected Health Information (PHI)
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| the HIPAA Privacy Rules specifies that PHI must be protected whether it is | written, spoken, or in electronic form
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| de-identified health information is | not considered PHI
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| HIPAA defers to laws of the state if state's laws are more stringent than HIPAA privacy standards | state preemption
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| put in force 2002, HIPAA gave physicians freedom to continue treating patients, seeking payment, & conducting routine healthcare operations without requiring written consent to conduct business of behalf of patient | Modification to the Privacy Rule
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| HIPAA privacy consent is not the same as | a Consent to Treat
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| means you can provide care, including coordination or management of health care between providers, or referring patient to another provider | treatment
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| within HIPAA means you can disclose PHI (name, address, date/birth, social security # & account number) to obtain reimbursement | payment
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| refers to activities including: quality assessments or improvements, reviewing competencies or qualifications of health care professionals, evaluating professional's performance, business mngmt & general admin. activities | healthcare operations
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| if you must defend an activity under HIPAA's healthcare operations category, before proceeding w/task, you should | clarify w/ privacy official or your attorney
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| is a requirement | standard
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| document including standards | rule
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| each rule starts out with a | Notice of Proposed Rule-Making (NPRM)
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| presents NPRM for public comment & revisions | US DHHS
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| final rules are published in the | Federal Register
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| deadline for compliance or implementation is 24 months after | a rule's effective date
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| a rule's effective date, may be 30-60 days after | publication date
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| in 1991 created to study what impact replacing paper healthcare transactions would have on containing rising healthcare costs | Workgroup for Electronic Data Interchange (WEDI)
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| foundation of Administrative Simplification provisions in HIPAA | 1993 WEDI report
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| guarantees that you can obtain insurance if you change jobs, first term of the title law | portability
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| begins to identify who/what should be accountable for specific healthcare activities, second term of the title law | accountability
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| Administrative Simplification was designed to address the health care | administrative systems & business issues
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| Administrative Simplification promises to make | business of health care easier
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| those data sets that identify diagnoses, treatment procedures, drug codes, equipment codes, & other codes | code sets
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| "Everyone must send or receive transactions using | standards formats & data content
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| process to handle industry recommended modifications to standard that may enhance administrative simplification | designated standard-maintenance organization (DSMO)
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| outcome of ___ practices will have to ensure their software vendors can send/receive info using standard data formats & data content | Transactions and Code Sets Rule
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| requires PHI secure at rest, movement, or in | electronic, oral, written format
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| only the __ __ can know everyone's passwords | system administrator
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| about controlling access to PHI | security
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| about controlling how electronic, oral, & written PHI is used & disclosed | privacy
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| a practice immediately became obligated to build program that protects security of personal health information when | HIPAA was signed into law
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| within the __ __ are standards that say practices must "safeguard" or protect medical records | Privacy Rule
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| published in Federal Register 2/20/03, including administrative, physical & technical safeguards pertaining to electronic PHI that must be in place no later than 4/21/05 | final Security Rule
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| requires similar safeguards, to the final Security Rule, for not only electronic PHI but also oral & written PHI & must be in compliance by 4/14/03 | the Privacy Rule
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| rooms & storage facilities w/locks or other safeguards that control access are considered ___ safeguards | physical
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| policies & procedures defining who has access to info, user IDs, passwords, & actions if violations occur are considered | administrative safeguards
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| encryption of electronic data & use of passwords to verify users who have logged onto a system are considered | technical safeguards
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| security is an ongoing process that is | never done
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| are based on the principle of "reasonableness" given size/complexity of environment in which covered entity operates | privacy & security rules
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| as a foundation for developing a practice's polices & procedures ___ ___ must be conducted | risk analyses
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| as a foundation for developing a practice's polices & procedures determination of how to __ __ from the risk analyses | mitigate risks
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| Your first priority is to develop a way to quantify & evaluate ___ | risk
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| you need to know what you are protecting & how much it is worth before you can decide | how to protect it
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| even though there are federal penalties for noncompliance w/privacy & security rules, HHS' focus is to encourage | voluntary compliance
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| www.hhs.gov/ocr provides | guidance on privacy
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| www.cms.gov/hipaa provides | questions & guidance on security
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| under the final Security rule HIPAA will require every healthcare provider to put several layers of | safeguards in place
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| "reasonable & appropriate" administrative, technical & physical safeguards will vary depending on | area located and scope of technology used
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| product must be certified as defined by federal government, product can do e-prescribing, product is interoperable, & product has necessary clinical decision support to rpt on key clinical indicators as being rptd by government | HITECH provisions of ARRAs meaningful use
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| key terminology for all medical providers to be able to gain their Medicaid/Medicare incentives, a key benchmark within the HITECH provisions of ARRA | meaningful use
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| responsible for defining meaningful use | Office of the National Coordinator
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| responsible for rolling out specific provisions of HITECH ARRA | Secretary of Health & Human Services
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| a number of health insurance carriers will be moving to a an HITECH platform, which is a | valid program around patient centered medical home
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| gathers necessary the care of the patient, combines it together in a data repository, provides meaningful, timely, accurate info to develop a very effective plan of care, & kept by primary care physician | patient centered medical home
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| patient centered medical home differs from managed care in that the primary physician does not select referring doctors responsible for care for care, but rather responsible for | where all that care is coordinated
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| reduce reliance on necessary tests, potentially unnecessary hospitalizations, unnecessary follow-up visits to doctors because care/tests already rendered; quicker path to diagnosis | idea behind patient centered medical home
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| must be actively engaged in use HIT product | meaningful user
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| to determine physical safety of patient info, the security official is required to conduct a | risk analysis & regular audits
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| administrative actions, & policies & procedures, to manage selection, development, implementation, & maintenance of security measures to protect electronic PHI & to manage conduct of covered entity's workforce in relation to PHI | administrative safeguards
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| property that "data/info is accessible & usable upon demand by an authorized person" | availability
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| property that "data/info is not made available or disclosed to unauthorized persons or processes" | confidentiality
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| health plans, healthcare clearinghouses, & healthcare providers that transmit any health info in electronic form under the transactions standards | covered entities
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| PHI that meets requirements of (i) transmitted by electronic media, or (ii) maintained in electronic media, of the PHI definition | electronic protected health information (EPHI)
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| electronic storage media, transmission media used to exchange ePHI already in electronic storage media, & other ePHI transmissions (to the extent any ePHI transmitted via these means originates or is received as data in electronic storage media) | electronic media
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| algorithmic process to transform data into form in which low probability of assigning meaning w/out use of confidential process/key | encryption
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| using confidential process/key to transform information into the original data | decryption
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| physical measures, policies & procedures to protect covered entity's electronic info systems & related buildings & equipment from natural or environmental hazards & unauthorized intrusion | physical safeguards
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| property that "data/info has not been altered or destroyed in an unauthorized manner" | integrity
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| individually identifiable health info that is (i) transmitted by electronic media; (ii) maintained in electronic media; (iii) transmitted/maintained in any other form or media | protected health information (PHI)
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| requires implementation by covered entity | required implementation specification
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| allows covered entity to determine "whether each implementation specification is reasonable/appropriate safeguard in its environment, when analyzed w/reference to likely contribution to protecting entity's EPHI" | addressable implementation specification
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| administrative, physical & technical safeguards are the | 3 types of security standards
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| security standards will supersede any contrary provision of | State Law
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| security standards establish a __ level of security that covered entities must meet | minimum
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| compliance with Security Rule is designed to provide a ___ ___ of all EPHI | floor protection
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| the Security Rule is considered | technologically neutral
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| the Security Rule does not dictate what ___ ___ to make | technology choices
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| the Security Rule dictates what ___ to achieve | protections
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| under Security Rule standards, technology choices are considered | inputs
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| under Security Rule standards, protections are considered | outputs
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| security protections must be reasonable & appropriate, as assessed in the required risk analysis & study of rick-management measures | foundation of Security Rule
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| the Security Rule is designed to be | scalable & flexible
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| implementation of security rule standards will be reflected in policies & procedures which must be kept current & retained | for six years from creation date or date last in effect
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| documentation must be created & maintained that memorializes ___ ___ & ___ pertaining to the Security Rule | actions, activities, & assessments
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| should be carefully constructed, documented in writing, updated as appropriate & retained for 6 years in accordance w/HIPAAs documentation standard | required risk analysis
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| the required risk analysis will focus attention on ___ potential business risks | mitigating
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| the required risk analysis will help find solution that | will benefit the workforce
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| National Institute of Standards & Technology | NIST
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| NIST is part of | US Dept of Commerce
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| "likelihood of a given threat-source;s exercising a particular potential vulnerability, & resulting impact of that adverse event on the organization" | NIST definition of risk
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| general requirements, flexibility of approach, standards, implementation specifications, & maintenance are | 5 general rules in Security Rule
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| ensure confidentiality, integrity & availability of EPHI created, received, maintained, or transmitted; protect against reasonably anticipated threats/hazards, disclosures; & ensure compliance | four general requirements in general rules of Security Rule standards
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| size, complexity & capabilities; technical infrastructure, hardware, & software security capabilities; cost of security measures; probability of criticality of potential risk to EPHI by covered entity | reasonable & appropriate security measures factors
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| failure to comply with Security Rule standard leads to liability for | civil sanctions & potential loss of business
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| covered entity must balance the safeguard specification w/degree of __ __ the specification affords | risk mitigation
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| requires covered entity review security measures periodically & make modifications necessary to ensure providing "reasonable & appropriate protection of EPHI" | maintenance
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| there are nine ___ safeguard standard | administrative
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| implement policies & procedures to prevent, detect, contain & correct security violations; manage security risk, sanctions as disincentive for noncompliance, & periodically review security controls | Standard: Security-Management Process
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| Standard: Security-Management Process | "form the foundation upon which an entity;s necessary security activities are built"
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| risk analysis, risk management, sanction policy, & information system activity review are __ implementation specifications | required
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| identify security official responsible for development & implementation of policies/procedures required by Security Standards for Protection of EPHI; required implementation specification | Standard: Assigned Security Responsibility
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| implement policies/procedures for authorization and/or supervision of personnel who work w/or in locations were EPHI might be accessed | Standard: Workforce Security Authorization and/or Supervision - addressable
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| when there are addressable implementation specifications it is required that standard compliant policies & procedures be | documented in writing
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| implement procedures to determine that access of personnel access to EPHI is appropriate | Standard: Workforce Security; Workforce Clearance Procedure - addressable
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| implement procedures for terminating access to EPHI when termination of employment | Standard: Workforce Security; Termination Procedure - addressable
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| purpose of termination procedure documentation is to ensure that termination procedures include ___ action to be followed | security-unique
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| implement policies & procedures for authorizing access to EPHI consistent w/applicable requirements of Privacy of Individually Identifiable Health Information | Standard: Information Access Management
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| Isolating Healthcare Clearinghouse Functions is a ___ implementation specification of Standard: Information Access Management | required
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| implement policies & procedures for granting access to EPHI; addressable implementation specification of Standard: Information Access Management | Access Authorization
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| implement policies & procedures per access-authorization policies, establish, document, review, & modify user's right/access to workstation, transaction, program & processes; addressable implementation spec. of Standard: Information Access Management | Access Establishment & Modification
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| implementation of security awareness & training program for all members of workforce, including management; 4 addressable implementation specifications | Standard: Security Awareness & Training
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| periodic security updates; addressable implementation spec. of Standard: Security Awareness & Training | Security Reminders
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| procedures for guarding against, detecting & reporting malicious software; addressable implementation spec. of Standard: Security Awareness & Training | Protection from Malicious Software
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| procedures for monitoring log-in attempts & reporting discrepancies; addressable implementation spec. of Standard: Security Awareness & Training | Log-in Monitoring
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| procedures for creating, changing, & safeguarding passwords; addressable implementation spec. of Standard: Security Awareness & Training | Password Management
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| security training is dependent on entity's | configuration and risk
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| 1st goal of security training is | awareness
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| although an entity is not responsible for providing training outsides of it's workforce, they are responsible for ensuring that __ __ are aware of entity's security policies & procedures | business associates
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| CSRC | Computer Security Resource Center
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| Computer Security Resource Center is part of | National Institute of Standards & Technology
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| National Institute of Standards & Technology | NIST
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| Information Technology Security Training Requirements | special publication of NIST
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| awareness programs set the stage for training by changing organizational attitudes to realize the importance of security and the | adverse consequences of its failure
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| purpose of awareness training it to teach people skills that will | enable them to perform jobs more effectively
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| 2 important attributes if of successful awareness & training program | change in corporate culture & greater staff productivity
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| management play an important role in effecting change & | realizing the payoff
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| implement policies & procedures to address security incidents; one required implementation specification | Standard: Security Incident Procedures
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| attempted/successful unauthorized access, use, disclosure, modification, or destruction of info or interference w/system operations in an info system | security incident
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| identify & respond to suspected/known security incidents; mitigate to extent of practicable, harmful effect of security incidents known to covered entity; document incidents & outcomes | Response & Reporting
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| covered entity's are required to respond & mitigate any __ __ of security incidents | harmful effects
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| establish (implement as needed) policies & procedures for responding to emergency/other occurrence that damages systems that contain EPHI; 5 implementation specifications (3) required (2) addressable | Standard: Contingency Plan
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| establish & implement procedures to create & maintain retrievable exact copies of EPHI; required implementation specification of Standard: Contingency Plan | Data Back Up Plan
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| establish (implement as needed) procedures to restore any loss of data; required implementation specification of Standard: Contingency Plan | Disaster Recovery Plan
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| when preparing a disaster recovery plan, covered entity should examine __ __, even though the probability may be low | worst-case scenarios
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| EHNAC | Electronic Healthcare Network Accreditation Commission
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| has identified several key components to a disaster-recovery plan that mitigate business interruption | ENHAC
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| will be outgrowth of the identification of threats in the risk analysis | disaster recovery planning
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| determine outcomes for each of the threats& impact on the | operations of the practice
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| the final rule of the disaster recovery plan calls for covered entities to consider how natural disasters could damage systems that contain EPHI & develop policies & procedures for responding to these situations; these are considered to be | a reasonable precautionary step
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| establish (implement as needed) procedures to enable continuation of critical business processes for protection of security of EPHI while operating in emergency mode; required implementation specification of Standard: Contingency Plan | Emergency Mode Operation Plan
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| important to get input from each workforce member of duties/workflow in order to establish a | workable emergency mode operation plan
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| implement procedures for periodic testing/revision of contingency plans; addressable implementation specification of Standard: Contingency Plan | Testing & Revision Procedures
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| assess relative criticality of specific applications & data in support of other contingency-plan components; addressable implementation specification of Standard: Contingency Plan | Applications & Data Criticality Analysis
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| because Security Rule pertains to EPHI, the loss of ___ is critical & should be dealt w/in a covered entity's risk analysis | electricity
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| perform a periodic technical & non technical evaluation; establish extent to which entity's security policies/procedures meet requirements of Security Standards for Protection of EPHI | Standard: Evaluation
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| Standard: Evaluation implementation specification is | reflected in the standard & is required
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| in accordance w/general rules of security standard, may permit business associate to create, receive, maintain, or transmit EPHI on entity's behalf | Standard: Business-Associate Contracts & Other Arrangements
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| must provide satisfactory assurances that they will protected EPHI | business associates
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| document satisfactory assurances through written contract/other arrangement that meets applicable requirements as part of Organizational Requirements; required implementation specification of Standard:Business-Associate Contracts & Other Arrangements | Written Contract/Other Arrangement
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| physical measures, policies, & procedures to protect a covered entity's electronic-information systems & related buildings & equipment from natural & environmental hazards, & unauthorized intrusion | physical safeguards
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| implement policies/procedures to limit physical access to electronic-information systems & facility(s) in which housed, while ensuring properly authorized access is allowed | Standard: Facility Access Controls
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| establish (implement as needed) procedures allowing facility access in support of restoration lost data under disaster-recovery plan & 911-mode operations plan in event of 911;addressable implementation specification of Standard: Facility Access Controls | Contingency Operations
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| implement policies & procedures to safeguard facility & equipment therein from unauthorized physical access, tampering, & theft; addressable implementation specification of Standard: Facility Access Controls | Facility Security Plan
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| implement procedures to control/validate person's access to facilities based on role/function, incl. visitors, & to software programs for testing/revision; addressable implementation specification of Standard: Facility Access Controls | Access Controls & Validation Procedures
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| implement policies/procedures to document repairs & modifications to physical components of facility related to security; addressable implementation specification of Standard: Facility Access Controls | Maintenance Records
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| Standard: Facility Access Controls applies to a covered entity's facility or | facilities
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| under Standard: Facility Access Controls facility includes physical premises and | interior/exterior of buildings
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| under Standard: Facility Access Controls is extended to include premises of workforce members who work __ __ with EPHI | at home
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| under Standard: Facility Access Controls a covered entity retains responsibility for considering facility security even where | it shares space with other organizations
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| under Standard: Facility Access Controls a covered entity must document in their risk analysis | third-party security measures
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| implement policies/procedures that specify proper functions to be performed, manner those functions to be performed & physical attributes of surroundings of specific workstation(s) that can access EPHI | Standard: Workstation Use
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| receptionist areas, in a private practice, __ __ __ __ to patients signing in w/receptionist | may not be visible
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| in a private practice, workstations throughout the practice should not be visible to any | passerby
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| implement physical safeguards for all workstations that access EPHI to restrict access to authorizes users; implementation is dependent upon entity's risk analysis & risk management process | Standard: Workstation Security
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| implement policies/procedures the govern receipt & removal of hardware & electronic media containing EPHI into & out of a facility & movement of these items within facility; 4 implementation specifications (2) req & (2) addressable | Standard: Device & Media Controls
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| implement policies/procedures to address final disposition of EPHI &/or hardware/electronic media on which it is stored; required implementation specification of Standard: Device & Media Controls | Disposal
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| implement policies/procedures for removal of EPHI from electronic media before media are made available for reuse; required implementation specification of Standard: Device & Media Controls | Media Reuse
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| Maintain record of movements of hardware/electronic media & any person responsible for them; addressable implementation specification of Standard: Device & Media Controls | Accountability
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| create retrievable, exact copy of EPHI when needed, before movement of equipment; addressable implementation specification of Standard: Device & Media Controls | Data Backup & Storage
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| even though software may claim to delete files, it may only deleted the __ __ & not erase the underlying content | file name
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| Accountability implementation specification does not refer to | audit trails within system/software
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| Accountability implementation specification does refer to | record of actions of a person relative to receipt/removal of hardware/software into & out of facility-traceable to that person
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| consists of technology & policy/procedures for its use that protect EPHI & control access to it; 5 safeguard standards | Technical Safeguards
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| implement policies/procedures for electronic info systems that maintain EPHI to allow access only to those persons/software programs that are granted access right per Administrative Safeguards standard of Info Access Mngmt | Standard: Access Control
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| each of implementation specifications under Standard: Access Control require technical assistance from | entity's system administrator/practice-management vendor
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| assign a unique name &/or # for identifying & tracking user identity; required implementation specification of Standard: Access Control | Unique User Identification
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| establish (implement as needed) procedures for obtaining necessary EPHI during 911 situation; required implementation specification of Standard: Access Control | Emergency Access Procedure
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| implement electronic procedures that terminate an electronic session after predetermined time of inactivity; addressable implementation specification of Standard: Access Control | Automatic Logoff
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| implement mechanism to encrypt/decrypt EPHI; addressable implementation specification of Standard: Access Control | Encryption & Decryption
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| implement hardware, software, &/or procedural mechanisms that record/examine activity in information system that contain/use EPHI | Standard: Audit Controls
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| according to preamble to Security Rule Standard: Audit Controls is mandatory; however entity's have flexibility to implement | in manner deemed appropriate by their risk analyses
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| implement policies/procedures to protect EPHI from improper alteration/destruction; one addressable implementation specification | Standard: Integrity
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| mechanism to authenticate EPHI; corroborate EPHI hasn't been altered/destroyed in an unauthorized manner | addressable implementation specification of Standard: Integrity
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| error-correcting memory & magnetic disk storage are examples of | built-in data authentication mechanisms
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| implement procedures to verify a person/entity seeking access to EPHI is the one claimed | Standard: Person or Entity Authentication
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| biometric ID systems, password systems, personal identification #'s. telephone callback, physical/soft token systems & digital signatures are examples of | Person/Entity Authentication
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| implement technical security measures to guard against unauthorized access to EPHI being transmitted over an electronic communication network | Standard: Transmission Security
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| implement security measures to ensure electronically transmitted EPHI is not improperly modified w/out detection until disposed of; addressable implementation specification of Standard: Transmission Security | Integrity Controls
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| implement mechanism to encrypt EPHI whenever deemed appropriate; addressable implementation specification of Standard: Transmission Security | Encryption
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| it is the covered entity's responsibility to secure its | transmissions
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| An estimated 15-30% of every healthcare dollar goes towards | administration (i.e. claim review, software development
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| activities meant to make the claims process easier have become parts of | health care's administrative black hole
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| high $$ concerns for a medical office include | rick management & medical malpractice
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| HIPAA was developed by __ __ & __ __ within the US DHHS, along with executive from private healthcare sector | physician leaders & policy makers
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| 1991, a collaboration of government & private industry, Louis Sullivan created | Workgroup for Electronic Data Interchange (WEDI)
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| WEDI was developed to study what impact replacing paper healthcare transactions would have on | containing rising healthcare costs
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| became foundation of the Administrative Simplification provisions in HIPAA | WEDI 1993 landmark report
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| guarantees you can obtain insurance if you change jobs | Portability
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| identifies who & what should be held responsible for specific healthcare activities | Accountability
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| Administrative Simplification promises to make the business of healthcare | easier
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| simplifies transactions so that all entities filing electronic transactions use same code sets, data content, & data format, & keep patient info safe/secure | purpose of Administrative Simplification
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| systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge | research defined by Privacy Rule
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|
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| distinction between research activity & healthcare operations activity is whether the activity is designed to | develop or contribute to generalizable knowledge
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|
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| require covered entity to obtain a detailed written authorization form from the patient, in order to satisfy all required elements of an applicable exception to the authorization requirement, under the Privacy Rule, when conducting | a research activity
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|
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| Privacy Rule permits a covered entity to carry out its own health care operations w/out any form of patient permission & without any restrictions in the | use or disclosure of PHI
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|
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| HHS drafted Privacy Rule in a manner that retains more stringent protection for the use/disclosure of PHI for __ __ than other health care operations activities | research purposes
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|
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| if a covered entity uses/discloses only a limited data set of information pursuant to a data use agreement they may | use or disclose PHI for research activities
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| a covered entity may use or disclose PHI for research activities if the review of PHI is | preparatory to research
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|
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| a covered entity may use or disclose PHI for research activities if the research is | on decedents' information
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|
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| a covered entity may use or disclose PHI for research activities if institutional review board (IRB) or privacy board has approved | a waiver of or an alteration to the authorization
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|
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| covered entities are always free to use & disclose information that has been | sufficiently de-identified
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|
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| when covered entity removes all of a list of enumerated identifiers from PHI & covered entity has no actual knowledge that remaining info could be used alone or in combination w/other info to identify subject of info, is known as | "safe harbor" method
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|
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| 2nd method to de-identify involves a person w/knowledge of & experience w/statistical & scientific principles must document methods & results of analysis that justify the determination that | the risk of identification is small
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|
||||
| also known as retrospective, archival, or non-interventional research | records research
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|
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