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CMS’ HIPAA Risk Analysis Myths and Truths

Posted on October 21, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I’ve been writing about the need to do a HIPAA Risk Assessment since it was included as part of meaningful use. Many organizations have been really confused by this requirement and no doubt it will be an issue for many organizations that get a meaningful use audit. It’s a little ironic since this really isn’t anything that wasn’t already part of the HIPAA security rule. Although, that illustrates how well we’re doing at complying with the HIPAA security rule.

It seems that CMS has taken note of this confusion around the HIPAA risk assessment as well. Today, they sent out some more guidance, tools and resources to hopefully help organizations better understand the Security Risk Analysis requirement. Here’s a portion of that email that provides some important clarification:

A security risk analysis needs to be conducted or reviewed during each program year for Stage 1 and Stage 2. These steps may be completed outside OR during the EHR reporting period timeframe, but must take place no earlier than the start of the reporting year and no later than the end of the reporting year.

For example, an eligible professional who is reporting for a 90-day EHR reporting period in 2014 may complete the appropriate security risk analysis requirements outside of this 90-day period as long as it is completed between January 1st and December 31st in 2014. Fore more information, read this FAQ.

Please note:
*Conducting a security risk analysis is required when certified EHR technology is adopted in the first reporting year.
*In subsequent reporting years, or when changes to the practice or electronic systems occur, a review must be conducted.

CMS also created this Security Risk Analysis Tipsheet that has a lot of good information including these myths and facts which address many of the issues I’ve seen and heard:
CMS HIPAA Security Risk Analysis Myths and Facts

Finally, it’s worth reminding people that the HIPAA Security Risk Analysis is not just for your tech systems. Check out this overview of security areas and example measures to secure them to see what I mean:
CMS HIPAA Security Risk Analysis Overview

Have you done your HIPAA Risk Assessment for your organization?

HIPAA Risk Assessment Infographic

Posted on July 25, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I’ll admit that I’m a sucker for infographics. I usually post the various EHR infographics I find on EMR Thoughts, but this one seemed more appropriate to post on EMR and HIPAA. You can find all of the various EHR and Health IT infographics I’ve posted on this Healthcare IT Infographic pinterest board as well.

Thanks to Coalfire for putting together this HIPAA Security Risk Analysis Myths infographic.

Update: David Harlow offered this interesting note that might be helpful to some “The infographic suggests that only covered entities need to undergo a security risk assessment. In the EHR context that makes sense, since them with EHRs are CEs, but of course Business Associates need to do this too.”

HIPAA Risk Assessment Infographic