CMS Investigation Guidance for HIPAA Compliance
Brought to you by: Ali Pabrai, CISSP, CSCS, HIPAA Academy

The CMS web-site provides details about key personnel that may be interviewed and important documents that would be reviewed during a HIPAA Security audit. In this HIPAA and Security Tip, we examine key documents that would be reviewed as part of a CMS HIPAA Security on-site investigation and compliance review.

Documents and other information that may be requested by CMS for HIPAA investigations and reviews include policies, procedures and other evidence that address the following partial list:
-Prevention, detection, containment, and correction of security violations
-Detecting, reporting, and responding to security incidents (if not in the security plan)
-Encryption and decryption of EPHI
-Mechanisms to ensure integrity of data during transmission - including portable media transmission (i.e. laptops, cell phones, blackberries, thumb drives)
-Disposal of media and devices containing EPHI

Has your organization developed these policies, procedures and other documents as identified by CMS? Contact ecfirst to Discuss Compliance with the HITECH Act and HIPAA Regulations

To discuss your challenges complying with the HITECH Act and the HIPAA regulation contact Steve Ferrick@ecfirst.com or call 1.877.899.9974 x14. Ask Steve for a complimentary copy of the executive brief, “Are Medical Records At Risk?” In this brief you will find the CMS issued guidance that provides insight on HIPAA investigations and audits. Talk to us about our exclusive Managed Compliance Services Program (MCSP) and other HITECH & HIPAA consulting solutions including development of a proposal for addressing your contingency planning and enterprise security requirements.

AHA Solutions provides outstanding, complimentary educational events, including these upcoming webinars and audioconferences:

Medicare and Medicaid Program Integrity Contractors (MACs, RACs, MIPs, MIGs, etc): Making Sense of the Alphabet Soup!
Wednesday, May 13, 2009
1:00 pm (EDT), 12:00 pm (CDT), 10:00 am (PDT)
1 hour
Register Now
-Describe the role of MACs, RACs, PSCs, ZPICs, CERT, MIP, MICs,PERM and MIGs
-Recognize the individual Program Integrity Contractors’ findings and how they interrelate
-Discuss the current status of these programs
-Identify the direct hospital and provider impact of current regulatory enforcement initiatives
-Determine how to prioritize your focus among these auditing bodies to assess the greatest threats and opportunities for ensuring revenue integrity

State Security Regulations & HITECH – Complying with Increased Mandates for Privacy
Thursday, May 21, 2009

1:00 pm (EDT), 12:00 pm (CDT), 10:00 am (PDT)
1 hour
Register Now

-Walk through several State regulations and their mandates for increased privacy and security
-Examine new requirements in the HITECH Act for covered entities, business associates and vendors
-Review new enforcement approaches as well as the tiers of penalties that have been defined
-Step through significant requirements introduced for breach and notification
-Understand how to prepare for an audit by organizations such as the OCR, CMS, OIG or the FTC

Linking Telemedicine and the EMR to Improve Care for Communities
Thursday, June 18, 2009

1:00 pm (EDT), 12:00 pm (CDT), 10:00 am (PDT)
1 Hour
Register Now

This webinar will discuss how the use of telemedicine allows hospitals to improve and utilize their EMRs to create a more comprehensive Health Information Exchange (HIE) to improve the quality of care which supports your efforts towards the American Recovery and Reinvestment Act (ARRA) and the Stimulus package. 

The following showcases a variety of resources you can use to stay up-to-date with IT issues!

Survey Results:
The High Cost of Nurses’ Communication Challenges
More than 250 practicing nurses participated in a 2009 survey commissioned by Cisco. The survey was designed to identify the impact of communication challenges in hospitals. The result show that communication lapses take a heavy toll on key C-suite priorities including clinician productivity, patient safety, and the patient experience.

To get a copy of the survey and detailed findings, click here.

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Article:
Managing the Policy and Procedure Puzzle

Successfully assembling all of the pieces of policy and procedure documentation is a puzzle for many organizations but it does not have to be.  Within this article learn several tips and tricks on making this strenuous process easier. Learn short-cuts to policy and procedure management from PolicyTech!

For a copy of the complete article, email technologysolutions@aha.org
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Survey Results:
Corporate Gifts & Entertainment: A Survey of Practices
A survey by the Health Care Compliance Association & The Society of Corporate Compliance and Ethics
“Despite the reports of lavish executive pay, when it comes to entertainment and gift giving, the business world may be far less generous than people think. A survey of compliance and ethics professionals revealed that, on the whole, business is fairly restrictive of the gifts employees can give and receive and how they can entertain.
Still, the data revealed areas of inconsistency. On balance, the healthcare industry was far more restrictive than industry as a whole in these areas, and there were differences between the for and non-profit sectors of the economy.
Perhaps most intriguing of all is the fact that most companies have not revised their gifts and entertainment policy significantly since the meltdown. While the data does not show that companies are entertaining lavishly, at least not as a rule, there may be a need to revisit policies in light of changes in the economy.”

For a copy of the complete survey and detailed findings, email technologysolutions@aha.org
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Partner Profile:
Cisco Wireless Networking Products have the exclusive endorsement of the AHA.
If you attended HIMSS09, we hope you had a chance to visit the Cisco booth to see how Cisco Healthcare Solutions can help you to reduce costs, improve productivity and deliver better care. This year, there were a host of new solutions to see in the Cisco booth, including:  
-Cisco TelePresence offers healthcare providers a new way to communicate and collaborate with an "in-person interaction experience," irrespective of distance or location.
-Named one of the top-25 solutions to see at HIMSS09, Cisco Nurse Connect integrates nurse call systems with the Cisco Unified Wireless IP Phones 
-Cisco Context-Aware Temperature Monitoring triggers an alert if the temperature reported by a wireless RFID tag goes outside a user-definable range.
-The Cisco Biomedical Network Admission Control (NAC) solution automates the management of biomedical devices on your hospital network.    

Click here to visit the Cisco post-show site and to learn more about Cisco Healthcare Solutions.