When Chris Apgar, CISSP, president of Apgar & Associates in Portland, OR, conducts audits of healthcare organizations, he usually finds problems in five areas.
Many organizations are focusing on the new privacy and security requirements created by the Health Information Technology for Economic and Clinical Health (HITECH) Act. However, they also must measure their overall compliance with HIPAA requirements already on the books, says Apgar.
Facilities and organizations considering what to do next should concentrate on compliance in these five areas, says Apgar:
Lack of a risk analysis. Organizations either haven't conducted a risk analysis or, they last conducted one in 2005 when the HIPAA rule became final, he says. A risk analysis is "the foundation for your security program," he says. "You need that to build on."
Undocumented policies and procedures. Organizations may be doing the right thing, but they haven't documented it in their policies and procedures, he says. Less frequently, organizations do not follow proper procedures and don't have anything in writing.
Lack of training. Organizations may train new staff members, but many don't provide ongoing training, or the training they offer is often out-of-date, he says.