Our partner Elizabeth Litten and I were recently featured again by our good friend Marla Durben Hirsch in her article in the April 2017 issue of Medical Practice Compliance Alert entitled “Business associates who farm out work create more risks for your patients’ PHI.” Full text can be found in the April, 2017 issue, but

It was nearly three years ago that I first blogged about the Federal Trade Commission’s “Wild West” data breach enforcement action brought against now-defunct medical testing company LabMD.   Back then, I was simply astounded that a federal agency (the FTC) with seemingly broad and vague standards pertaining generally to “unfair” practices of a business entity

According to the latest HIPAA-related guidance (Guidance) published by the U.S. Department of Health and Human Services (HHS), a cloud service provider (CSP) maintaining a client’s protected health information (PHI) is a business associate even when the CSP can’t access or view the PHI. In other words, even where the PHI is encrypted

The aftermath of the Orlando nightclub tragedy has led to much discussion about ways that healthcare providers can and should deal with compliance with health information privacy requirements in the face of disasters that injure or sicken many individuals in a limited time frame. One aspect is the pressure to treat patients while simultaneously fulfilling

We blogged on this back in early May, but compliance with individuals’ rights to access their PHI under HIPAA is even more critical now that OCR has announced that its current HIPAA audits will focus on an audited Covered Entity’s documentation and process related to these access rights.

In an email sent to listserv participants

Contributed by Elizabeth R. Larkin and Jessica Forbes Olson

Health care providers know about and have worked with HIPAA privacy and security rules for well over a decade. They have diligently applied it to their covered entity health care provider practices and to their patients and think they have HIPAA covered.

What providers may not

My heart goes out to any family member trying desperately to get news about a loved one in the hours and days following an individual or widespread tragedy, irrespective of whether it was triggered by an act of nature, an act of terrorism, or any other violent, unanticipated, life-taking event. My mind, though, struggles with