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

Implementations with external services & Testing

When implementing external services with clients (such as exposing an API to external clients), are there any HIPAA rules/regulations around testing the implementation in a non-prod environment before going live in production? Are there any concerns with PHI or security with testing an implementation (of say an API with an external client) directly in a production environment?

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Developers and HIPAA

web based CASE Management Tool

I have a web application that allows a patient and a doctor to create an account. the patient can upload his medical history and associate scanned files to his account. the patient then selects a doctor within the web application and invites him to have a look at his case files. we are hosting this on a hipaa compliant environment under a BAA agreement. I am the only administrator who manages the system and I manage ...more »

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Developers and HIPAA

Deceased patients

A patient that is deceased, son, wants records. There is no power of attorney or executor of the estate. The son gets an attorney, they send a request for all records. The release form attached has the son signature. Can we release it to them?

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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

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

Record, transfer and store mobile inbuilt sensor data

Hi, For a mobile chatbot health app that reads, transfers and stores (within and outside mobile phone in a cloud based server) sensor generated time series data of patients/consumers activities, events, etc.. which includes all data that can be captured by a mobile phone's, accelerometer, light, other sensors without patient/consumer intervention, can such sensor generated data be classified as personal identifiable information ...more »

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Developers and HIPAA

Incorrect certificate configured for web app

The wildcard certificate `*.ideascale.com` doesn't match the urls of the web app, `hipaaqsportal.hhs.gov` and some browsers (chrome, safari) won't allow access to the site without accepting the mismatched certificate warning/block. Please fix, doesn't represent all that well for a compliance site.

 

thanks

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Developers and HIPAA

Providers feed PHI to your system, does this mean you are a BA?

You have an app to manage chronic care that is primarily driven by the patient and requires patient persmission to share any data, but where providers can enter some data, such as messages, or some information related to the patient's medication. The system is offered independently from a covered entity. Just because providers enter some PHI in the system, are you seen as a BA covered, or you are not a BA as long as ...more »

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Developers and HIPAA

Does the name of a Health Insurance company constitute PHI?

Does having identifiable information of a person and the name of the health insurance company they are enrolled in (or name of other covered entity) constitute a PHI record? 1. Would a text message sent to an individual that includes the name of their health insurance company (but no other health information) be subject to HIPAA regulations? 2. Would a text message sent to an individual that includes the name of their ...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

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 »

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Developers and HIPAA

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 »

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Developers and HIPAA

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 »

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