Developers and HIPAA

Submitted by

Birthweights/Ages

Certain pediatric tasks require fairly precise ages, for example when evaluating jaundice one must know a baby's age in hours. What precautions are required to ensure that a birthdate cannot be inferred by usage data from an app that automates some of these tasks? For example, if a nurse enters in that a baby is 8 hours old, it seems a birthdate could be identified if the time of the nurse/app interaction was known. ...more »

Voting

1 vote
1 up votes
0 down votes
Answered Questions

Developers and HIPAA

Submitted by

When are end-user disclosures to a subcontractor not incidental?

I'm a compliance consultant for early stage startups with tight budgets. I'm not sure how to advise them regarding BAAs for third-party services such as customer support ticketing that aren't meant to collect PHI, but may incidentally. (E.g. "[Covered entity] entered my profile information wrong and I don't know how to change it. It should say...") These subcontractors meet the NIST definition of a cloud service provider, ...more »

Voting

1 vote
1 up votes
0 down votes
Answered Questions

Developers and HIPAA

Submitted by

Clarify the definition of PHI for online consumer interactions

I see a great deal of variation from organization to organization on what constitutes PHI in the digital realm. I have several scenarios that I'd like your thought on: - Is public website browsing behavior considered PHI as is suggested in the current Winston Smith V. Facebook case (http://digitalcommons.law.scu.edu/cgi/viewcontent.cgi?article=2175&context=historical)? This could impact a number of common services used ...more »

Voting

1 vote
1 up votes
0 down votes
Answered Questions

Developers and HIPAA

Submitted by

What is BAA to do with stored patient health info

The scenario is this: A private health clinic (PHC) signs up online to use a web-based EHR application to create patient charts, schedule patients, provide a patient portal, etc. - classic practice management tasks. The EHR vendor has a BAA with a company which hosts its web application and the encrypted database. My question is, what happens to the PHC's electronically stored ePHI if the PHC's account is cancelled and/or ...more »

Voting

1 vote
1 up votes
0 down votes
Answered Questions

Developers and HIPAA

Submitted by

Are we HIPAA compliant distributed team.

We are a small startup team that is distributed nationwide. To date everyone has used their own personal computers to login into work email, etc. Is it a requirement that we purchase and make all of our employees use only their work computers for development and access to our db? It's understood that we need a robust password policies and defined lists of who has access to any sensitive data where ever they may be.

Voting

1 vote
1 up votes
0 down votes
Answered Questions

Developers and HIPAA

Submitted by

Scanning and Penetration Testing

Do entities need to run internal and external vulnerability scanning be HIPAA compliant? Do entities have to run penetration tests to ensure compliance? Reading ยง164.312(e)(2)(i) it seems that 'security measures' could include these tests, but does not specify a requirement for it. Additionally, a risk analysis could identify that these services would help to reduce the risk, threats and vulnerabilities in-scope systems, ...more »

Voting

2 votes
2 up votes
0 down votes
Answered Questions

Developers and HIPAA

Submitted by

Data Masking in EMR

Data masking or controlled access provides a means for patients to control disclosure of select information within the EHR. http://www.nature.com/gim/journal/v10/n7/pdf/gim200876a.pdf Can patients request that access to sensitive data be controlled? Can patients request that only certain people can access their PHI? Can they request an audit of how their data has been shared by a covered entity? If so, do (or should) ...more »

Voting

0 votes
0 up votes
0 down votes
Answered Questions

Developers and HIPAA

Submitted by

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 »

Voting

3 votes
3 up votes
0 down votes
Answered Questions

Developers and HIPAA

Submitted by

Logging Activity within an Application

In order to be HIPAA compliant, should all activity that occurs with in an app be logged, or should activity that exceeds the normal threshold be logged? For instance, users that access information in the application routinely during the course of their work day will evince a regular level of activity. The activity will indicate routine access of sensitive information. Should the log contain all of the users activity, ...more »

Voting

3 votes
3 up votes
0 down votes
Answered Questions

Developers and HIPAA

Submitted by

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 »

Voting

1 vote
1 up votes
0 down votes
Answered Questions

Developers and HIPAA

Submitted by

Unencrypted PHI in the Cloud

From Kevin Wiggins, Saul Ewing: If a CE puts PHI on the Cloud and later terminates that Cloud as a service provider, there is inevitably some data remanence, thus leaving PHI on the Cloud. NIST Special Publication 800-80 addresses this by suggesting CEs use crypto-erase. What if the CE previously sent unencrypted PHI to the Cloud? Is it as simple as extending the protections of the contract to the information and ...more »

Voting

1 vote
1 up votes
0 down votes
Answered Questions