[ Friday, October 18, 2002 ]
From Phoenix Health System's weekly HIPAA e-mails:
*** Behind on Your HIPAA Compliance? Here's What to Do ***
So you missed the filing deadline to request an extension for compliance with the transactions regulations. And the privacy deadline is only six months away. Yet, you have not completed a gap analysis nor even begun planning your HIPAA strategy!
You're not alone -
According to the U.S. Healthcare Industry Quarterly HIPAA Survey Results (HIMSS and Phoenix Health Systems, Inc., Summer 2002), 80% of providers and 79% of payers have not completed their Transactions and Code Sets remediation AND Privacy remediation.
What do you do now? The first step should be to consult with your corporate legal staff about the matter. Then, you need to focus on HIPAA compliance.
At this point, the quickest and most effective way to achieve compliance may be through "negative" or non-compliance assumptions. Since there is not enough time to conduct a comprehensive gap analysis, you start from ground zero with your HIPAA strategic plan. Basically, you assume that you meet none of the regulatory standards and go from there. You move forward to implement HIPAA compliant processes throughout the organization, eliminating or altering any practices that are incongruent with your plan.
Whether you choose to engage third party assistance, or manage HIPAA implementation totally in-house, you still should immediately lay down the following groundwork:
Designate a privacy official
Designate assigned physical security responsibility
Form a HIPAA Steering Committee
Form Privacy, Security, Education, Business Associates, Transactions and Operations Teams
Investigate how many entities will be included.
Decide if you will develop and implement your HIPAA strategy as separate entities or as a formal healthcare organization.
Make sure your HIPAA Steering Committee, and all others charged with managing the implementation process, have a solid understanding of all appropriate HIPAA regulations.
The last point is critical. You can not afford to waste time planning organizational changes based on HIPAA mythology - get the facts! The final rules for Privacy, Transactions, Code Sets, and some of the Unique Identifiers have now been published. Make sure you understand the actual regulations, obtain appropriate legal counsel, and base your HIPAA implementation on the established laws.
The above steps will help you expedite the planning and implementation process.
Angie Atcher, Director
Phoenix Health Systems
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Jeff [8:36 AM]
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