Developers and HIPAA

Provider suggested use of an App - there is a breach

A provider or a wellness management company, which are both subject to HIPAA because they collect and house PHI. If that provider or wellness provider suggest to a patient that they use an app (the app was not developed for them and there has been no communication with the app company that the providers are going to use the app) to gather health data to share with them and the app company suffers a breach of information. ...more »

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Developers and HIPAA

BAAs with Vendors and Providers

If a company has a business associate agreement (BAA) with an electronic medical record (EMR) vendor, does that company also have to sign a BAA with each health care provider or provider group using that EMR in addition to their existing BAA with the vendor?

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Developers and HIPAA

Cloud computing

Developers need better guidance around cloud storage/computing and the Security Rule. Client-server architecture is no longer relevant in many cases. Health technology companies are typically now 100 percent cloud-based. Many clients are doing some type of data analytics work, or offer cloud-based EHRs and medical devices. HHS should provide good guidance for companies that are cloud based and virtual. Most companies ...more »

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Developers and HIPAA

Facility Directories

Can someone elaborate on what is allowed for facility directories under 164.510? The regulations say the directory can give the recipient the location of the patient (assuming all other requirements are met)? Can a covered entity (or its business associate) also give directions to the location? Can those directions be transmitted electronically (e.g., via e-mail or otherwise) to someone who asks for the patient by name ...more »

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Developers and HIPAA

HIPAA E-Signature Requirements

We are a small organization starting up a tele-health initiative. We would like to deliver a copy of our Notice of Privacy Practices electronically and have patients acknowledge receipt via check box prior to completing our online intake forms. This method is used for acceptance when one downloads software online. We are having a difficult time understanding the requirements for this. Can it be a check box and/or typed ...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

What part of the environment has to be compliant?

Does the entire environment need to be HIPAA compliant, or is it possible that the solution could fall into an exception to HIPAA, or can they use an API to store certain kinds of data? If you’re building modern technologies, you’re relying on a lot of third party (likely API) based services; mostly cloud based services. So which aspects of those need to be compliant?

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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

online social communities sponsored by a covered entity

We are a covered entity, and developing an online education program for a medical condition. Only registered/approved users are able to join view pages. So it may be assumed that a user has the medical condition, but the site does not require that users identify themselves to others. Users will have the option to enter PHI in a secured profile (hipaa compliant...), but can elect not to enter any info. The users will ...more »

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Developers and HIPAA

Is my App following acceptable security protocol through HIPPA?

I email addresses of the users of the app, which are all doctors not patients, for authentication purposes. The application uses SSL encryption for transmission of data between a user's phone and the backend servers. The data is not currently encrypted on the server, but will become encrypted in a future version. Security around the data is restricted such that a user can only access their own data and is not accessible ...more »

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Developers and HIPAA

When does a Patient Record(PR) become realized?

The topic came up in a planning session around the point in time when a PR becomes a PR. Let's say we are writing an app for first responders. If the user collects name, date of birth, and vital signs. Does the PR become legally protected as soon as the First name is collected, or is there some threshold of data size(fields, values, etc.) that indicates that the PR has been created in legal terms for HIPPA protection? ...more »

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