Best Practices For Complying With HIPAA & Safeguarding Patient PHI Accessible To Your Business Associates

Healthcare is expected to be the most targeted industry for cyberattacks in 2017, according to the 2017 Data Breach Industry Forecast from Experian. “Electronic health records stay likely to be a top target for hackers,” Experian found. To help expand heighten & complicate these dangers, providers’ duties for safeguarding personal health information (PHI) under medical Insurance Portability and Accountability Act (HIPAA) lengthen to certain vendors, referred to as “business affiliates (BAs)” in the HIPAA regulations. Healthcare, behavioral health insurance, and other organizations that maintain and process PHI have to have sound controls, guidelines, and procedures to protect patients’ PHI, and these settings, procedures, and methods must expand to all BAs who’ve access to PHI.

Who is a HIPAA Business Associate? A business affiliate is any business or person working in association with, or providing services to a covered entity (HIPAA-covered entities include health programs, clearinghouses, and healthcare providers using situations). A few of the most common BAs with usage of PHI include: lawyers, accountants, outsourced billing providers, consultants, data/cloud storage space vendors, contracted healthcare/ancillary service providers, translators/interpreters, IT suppliers, and claims/coding consultants.

AAFCPAs advise protected entities to apply a powerful HIPAA/PHI training and education program for all those people of the labor force. We recommend providers to develop and institutionalize a Risk Management Program also, including an ongoing risk assessment process. The risk management program & evaluation for HIPAA protected entities should incorporate BAs and the expansion of risk they pose for a health care organization.

One of the key themes within HIPAA is to limit the collection and transmitting of PHI to the minimum amount necessary. Providers should apply policies and settings that anonymizes key PHI to limit what is open to BAs. This is done through removing personal identifiers from reports provided to BAs, or by building parameters into electronic medical record (EMR) or other systems to limit identifiers or make them anonymous.

In many instances, PHI breaches take place in the transmission of data between health care organizations and their BAs. These transmissions happen at the beginning of the engagement with a BA typically, and towards the end of the engagement or task. AAFCPAs recommends that clients have an obvious knowledge of your BAs’ controls, techniques, and processes and the potential risks they create for the protected entity.

Providers will need to have compensating handles to ensure vendors and BAs are properly acquiring and transmitting PHI. Business associate agreements (BAAs) can be a critical tool for understanding & documenting these settings, processes and procedures, and in protecting PHI ultimately. AAFCPAs has highlighted for your consideration some best practice recommendations for mitigating the risk assumed by organizations through their BAs. AAFCPAs remind clients that it’s critical that transmissions of most PHI are finished with security at heart and by ensuring healthcare providers and BAs have email encryption and secure data transmitting protocols set up.

It is crucial that supplier organizations obtain signed BAAs before any PHI is sent to a BA. Healthcare organizations should ensure that BAAs are up to date annually, or periodically depending on changes with BAs, or stipulations within BAAs. BAAs may be in effect for a specific term, or cover the business and the BA in perpetuity, depending on the character of the services provided.

Consider customizing BAAs with respect to the consultant / service agency relationship. Customization may specifically determine terms, such as: the length of the project / engagement being performed, the level of usage of PHI directed at the BA, and approved uses of the PHI. BAs utilize subcontractors to execute services Often.

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BAs must integrate subcontractors into BAAs when relevant, and the covered entity should understand the BA’s controls over transmission of PHI to subcontractors. Make the BAA as part of your routine vendor or service agency on-boarding process, and new seller approval process, including carrying out criminal background checks as new BA romantic relationships arise potentially. Healthcare providers should execute a periodic inventory of vendors to determine if they get access to or ownership of PHI and conclude whether a BAA has needs or obtained updating.

A significant risk with PHI is that BAs may preserve PHI in secure directories or machines well after the conclusion of the engagement or project and following the BAA effective period has lapsed. Healthcare organizations should stipulate best practices of their BAAs to ensure BAs are properly protecting PHI. Some of these best practices include the secure storage of PHI, and damage of the PHI at the conclusion of any engagement or task with a BA. Consider getting confirmation from BAs when PHI is destroyed (and stipulating that requirement in the BAA).