Developers and HIPAA

Does HIPAA extend to untethered PHRs?

A software company (e.g. a startup) develops an untethered PHR that is offered directly to the patient (consumer). The patient then authorizes PHR to "request" and "pull" (on behalf of patient) all records from all portals offered by healthcare provider EHRs (e.g. by Epic (MyChart), Cerner,...etc). The PHR gets access to all portals using logon credentials provided by the patient (e.g. patient provides all usernames and ...more »

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Developers and HIPAA

EHR software partners uses third party API

Our EHR solution is partnering with another health related software company with a cloud based API product to provide additional solutions for providers. This is a seamless connection. Some PHI would be stored on the API cloud based system while our EHR would also store PHI either on the client server or the cloud. I have several questions. I am assuming that the business associate between our clients/providers ...more »

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Developers and HIPAA

How to handle old emails

I'm a web designer and have a client who has recently become hipaa compliant concerning his handling of email. He needed me to search his old emails from about 6 years ago for a certain file. Though he no longer uses that email address, the emails were still in webhosts database, and they were never hipaa compliant. He was wondering if he should just delete those old emails, since they are not hipaa compliant we thought ...more »

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Developers and HIPAA

Push Notifications

We have a communication platform where providers, patients, family members can connect and communicate securely. The patient can set their own preferences around how they receive notifications about types of messages, and from whom in the app. We would like to send the patient a push notification so they are aware there is a new message in the app. We can send a push notification that says" There is a new message in the ...more »

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Developers and HIPAA

Are CSPs that don't enforce ToS tacitly accepting a BA role?

I am a compliance consultant, seeing an increasing amount of concern from cloud service providers about customers/users sharing PHI via their platforms in clear violation of Terms of Service. (Depending on the platform, customers/users range from individuals to business associates to covered entities.) Specifically, the CSPs are concerned about whether allowing accounts in violation to remain active is somehow tacit acceptance ...more »

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Developers and HIPAA

Web app records meds, but not identifiable to patient.

I'm working on a free web application for use by healthcare providers that tracks the usage of antibiotics. I intend to make the application available to anyone as a tool without entering into any formal agreements. The tool would track such information as: facility census, medication name, dosage, date given, etc. patient age, gender, height, weight, etc. The tool would NOT use identifying information such as name, ...more »

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Developers and HIPAA

Must a mobile app PHR be password protected

A covered entity provides test results to patients through a Patient Mobile App or a Website. Patients must request access and data is transmitted securely. Once the patient has custody of the PHI (as a downloaded report on the website, or as received data on the mobile device, is the Covered Entity responsible if the patient loses their own data? Is it required, for example, that the Mobile App be password protected? ...more »

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Developers and HIPAA

Developers have full access to production phi at all times.

We are a small company but have our software in over 100 large hospitals. Our developers have full read-write access to all data in the production environment from the day they start (all environments actually). We also have un-encrypted / un-scrambled data in our stage and our certification environments. Each developer has 2 domain accounts, both have full read-write access to all data, an administrative account allows ...more »

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Developers and HIPAA

Connected Device Maintenance via App

A physician provides their patient with a medical device (like a CPAP or Glucose Meter). The company that created the medical device wants to monitor the maintenance of the machine. All of the information collected by the device that is sent to the physician is covered under a business associate agreement. Can the company that created the medical device receive information about the maintenance/operation of the device ...more »

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Developers and HIPAA

When is PHI de-identified?

We have developed a platform to facilitate the scheduling of transport/rides for patients to provider appointments. The process works as follows. The provider logs into a secure site, to schedule a ride to an appointment for a patient. The platform, at the appropriate time, sends formation to a rider service provider (someone such as Lyft, Uber, etc..) to schedule the transport. The information provide the transport ...more »

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Developers and HIPAA

HIPAA compliance with an task list from a provider?

I'm working on an app for a therapist to send a list of exercises to their patient's mobile device from their desktop for the patient to perform at home. The therapist can view if the patient is checking off their exercises and reporting thier completion each day. No information is being transmitted in regards to the patient's diagnosis or condition, only the list of exercises to be performed at home and the patient's ...more »

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Developers and HIPAA

Could a covered entity ever create a non-covered mobile app?

If a health care provider who is a covered entity were to create a general fitness/wellness app and silo off any collected data from their covered operations, could it be a valid hybrid entity? For instance, if a hospital creates a free meditation app but does not prescribe it as treatment, nor convey any data the app ingests back to medical professionals or EMRs, must the app still be HIPAA compliant? What are the criteria ...more »

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