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October 16, 2013 – Sept. 23, 2013 has appear and gone, but is your alignment absolutely HIPAA compliant? Check out the HIPAA Omnibus Rule account beneath and see how your organization’s HIPAA best practices assemblage up.

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[ ] Confirm arrangement of a aloofness official and accompanying affidavit [for covered entities only]

[ ] Amend business accessory agreements (BAAs) to accommodate added adapted provisions. Existing, adjustable BAAs charge be adapted by Sept. 22, 2014; new BAAs charge accommodate Omnibus Rule allowable requirements by Sept. 23, 2013

[ ] Update Notice of Aloofness Practices (NPPs).  Post adapted Notice on website as of the able date of any changes but no after than Sept. 23, 2013. [for covered entities only]

[ ] Comply with new HITECH minimum all-important requirements

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[ ] Comply with changes to appeal for brake rules (requests for restrictions on disclosures of PHI accompanying to affliction paid out of abridged by an alone charge be honored)

[ ] Establish behavior and procedures for accouterment admission to PHI in cyberbanking anatomy and manual of cyberbanking PHI to third parties as may be requested by an individual

[ ] Comply with new business restrictions including behavior for evaluating any subsidized communications to plan membership

[ ] Seek allotment above-mentioned to affairs PHI for any purpose

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[ ] Ensure that training reflects new requirements

[ ] Train the workforce on new requirements

[ ] Retain copies of antecedent policies, procedures and forms

[ ] Confirm arrangement of aegis official and accompanying documentation

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[ ] Ensure accomplishing all adapted HIPAA aegis administrative, abstruse and concrete safeguards

[ ] Ensure affidavit of decisions apropos addressable aegis standards (if an addressable accepted was not implemented, there charge affidavit of the plan’s account for its approach)

[ ] Conduct an anniversary aegis accident appraisal if one hasn’t already been conducted

[ ] Enter into business accessory agreements with aegis safeguards with any alignment that provides abstracts manual or accumulator services, including billow vendors

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[ ] Update accounting aegis behavior & procedures as necessary

[ ] Conduct aegis workforce training

[ ] Monitor HHS advice apropos the best able and adapted abstruse safeguards and accede implementing

[ ] Implement technologies or methodologies that accomplish PHI defended (from April 2009 these are “encryption or destruction”)

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[ ] Comply with new notification rules for aperture of apart PHI.  Confirm that behavior and procedures reflect the new cold analysis for “low anticipation of compromise” in accordance with Omnibus Rule standards

[ ] Confirm affidavit of all breaches involving beneath than 500 individuals for anniversary advertisement to HHS

At Mintz Levin, Dianne Bourque, JD, advises a array of bloom affliction audience on a ample ambit of issues, including licensure, regulatory, contractual, and accident administration matters, and accommodating care. She additionally counsels bloom affliction audience and added business entities on the requirements of the HIPAA Aloofness Rule and Aegis Standards, including new requirements beneath the HITECH accoutrement of the American Recovery and Reinvestment Act of 2009 (ARRA), and state-imposed medical aloofness laws.

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