Accounting of Disclosures under HIPAA: Review the proposed regulations

The HIPAA Privacy Rule, which went into effect in 2003, required that entities keep track of all the disclosures they make of Protected Health Information (PHI) outside of those necessary for Treatment, Payment, and Healthcare Operations (TPO). With Electronic Health Record (EHR) systems in place, which keeps a track of disclosures made for all reasons, including those for TPO, and a proposed regulation has been issued to implement the law.  The new regulation includes not only the removal of the exclusion for disclosures for TPO, but also a new individual right to an access report showing all accesses of any PHI held in the Designated Record Set.

Under the proposed regulation, individuals can request a full accounting of uses and disclosures, including TPO, from all kinds of electronic record systems and it has become important for every entity that maintains electronic records to get prepared to comply with such requests.

Jim Sheldon-Dean, in this 60 minute session will describe:

• How the rules of Accounting of Disclosures used to work, and what used to be necessary to be able to respond to requests for accountings. 
• How the proposed rule creates a new individual right to an access report.
• How systems and business processes may need to change to be able to produce an access report.
• How electronic health records change the landscape of accounting for disclosures and what the new electronic systems can keep track of.
• How having systems that meet HIPAA Security Requirements for auditing and activity review can help you meet the new requirements to account for all disclosures and track all accesses, even those for treatment, payment, and healthcare operations.
• What the new rules require you to do to respond to requests for accountings of disclosures and access reports and how that relates to the systems you use to track health information.
• What your systems vendors should be doing to help you meet the new requirements for accounting of disclosures and access reports.
• The format and content of the information that is provided to the individuals who ask for an accounting or an access report.
• The policies you need to support the new requirements of the law.

Who should attend? Compliance Manager, HIPAA Officer, Chief Information Officer, Health Information Manager, Medical Office Manager, Medical Practice Lawyer, CFO, CEO, COO. Privacy Officer, Information Security Officer.

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