Navigating HIPAA Compliance: Pt. 4 Information Access Management
Information Access Management (§164.308(a)(4))
At the heart of healthcare...
Adhering to HIPAA is challenging for executives, developers, and healthcare professionals.
Recognizing these challenges, our journey continues today with the principle of Information Access Management.
Information Access Management calls for us to acknowledge the importance of authorizing access to protected health information.
Say hello to valuable insights, actionable strategies, and real-world applications!
Isolate Clearinghouse Functions: When a healthcare clearinghouse is part of a larger entity, establish policies and procedures that safeguard the clearinghouse's PHI from access by the parent organization. If a clearing house does not exist, document it.
What is a healthcare clearinghouse?
A middleman between a healthcare provider and a health plan that checks claims from healthcare providers to ensure they don´t contain errors before forwarding them to a health plan for payment.
Or
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e.g., Think
Claims Processing Centers
Value-Added Networks (VANs)
Health Information Exchanges (HIEs)
Transcription Services
How do you isolate the clearinghouse? A few ways including:
Policies and Procedures: develop these to protect the ePHI of the clearinghouse from unauthorized access by the larger organization
Network Segmentation: use separate networks and systems for clearinghouse operations to reduce the risk of unauthorized access to PHI from other parts of the organization.
Physical Segregation: establish separate physical spaces for the clearinghouse operations to prevent unauthorized access to PHI. This involves dedicating specific rooms or buildings solely for clearinghouse activities and securing these areas with access controls such as keycard systems.
Business Associate Agreements (BAAs): ensure that BAAs are in place with all third parties that interact with the clearinghouse, including vendors, contractors, and other parts of the larger organization that may need access to PHI for legitimate purposes. Agreements should clearly delineate responsibilities regarding PHI protection and HIPAA compliance.
Limit PHI Disclosure: ensure that PHI is disclosed only on a need-to-know basis within the clearinghouse operations, strictly adhering to the 'minimum necessary' requirement under HIPAA, minimizing the risk of unnecessary exposure of sensitive information.
Hybrid Governance Structures are best suited for Isolation Strategies
Access Authorization: Develop Access Control policies & procedures to authorize, modify, and review workforce members, workstations, devices, etc. accessing ePHI.
ePHI is electronic protected health information
Develop policies and procedures for granting access to ePHI for the various ways such as access to a workstation, transaction, program, or other mechanism.
Use IAM automated systems to provide access to users, using the least privilege strategy.
Document a list of personnel with the authority to approve requests.
Document a list of personnel granted approval. This list can be used to cross reference access reviews.
Access Reviews: Regularly review authorization lists, personnel, & device access for accuracy.
Reviews should be conducted and documented on a routine basis (e.g., daily, weekly, quarterly.) This is not prescriptive but should be completed based on the risk to the organization
For example, a 2 person Business Associate will have a lower risk of unauthorized access vs a hospital with 100 workforce members. So the Business Associate may conduct reviews monthly vs weekly like the hospital
See you next week as we continue this journey together, breaking down the complexities of HIPAA into manageable, digestible pieces!
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