It seems everyone is moving to a new smart phone and wants to use it in all the incredible ways it can be used, including for health care purposes. New health care apps are being released all the time, and even good old e-mail is being used more and more to communicate, by providers and patients alike.
In order to integrate the use of mobile technology into patient communications, it is essential to perform the proper steps in an information security compliance process to evaluate and address the risks of using the technology. This session will describe the information security compliance process, how it works, and how it can help you decide how to integrate mobile technology into your organization in a compliant way. The process, including the use of information security risk analysis, will be explained, and the policies needed to support the process will be described.
But the process must also include consideration of various patient access requirements in the HIPAA Privacy Rule. There are new requirements to provide patients electronic access of electronically held PHI which raise new questions of how that access will be provided and how the information will be protected during and after access. And there has long been a HIPAA requirement for covered entities to do their best to meet the requests of their patients for particular modes of communication, and using a mobile device is no exception.
The stakes are high – any improper exposure of PHI may result in an official breach that must be reported to the individual and to the US Department of Health and Human Services, at great cost and with the potential to bring fines and other enforcement actions if a violation of rules is involved. Likewise, complaints by a patient if they are not afforded the access they desire can bring about HHS inquiries and enforcement actions, so it is essential to find the right balance of access and control.
HHS compliance audit activity and enforcement penalties are both increased, especially in instances of willful neglect of compliance, if, for instance, your organization hasn't adopted the complete suite of policies and procedures needed for compliance, or hasn’t adequately considered the impact of mobile devices on your compliance. Given that mobile devices are a leading source of breaches of PHI, it is essential to consider these devices and how their use affects the privacy and security of PHI; not doing so is inviting enforcement action by HHS.
The session will discuss the requirements, the risks, and the issues of the increasing use of mobile devices for patient communications and provide a road map for how to use them safely and effectively, to increase the quality of health care and patient satisfaction.
Areas Covered in the Session: