There’s a disconnect growing in the modern healthcare market – and it’s one that could soon see practitioners and covered entities alike hit with massive fines for noncompliance. I’m speaking about electronic health records (EHRs). As more and more hospitals and health organizations move forward with modern technology, healthcare data is increasingly digitized.
On the one hand, that’s great. It means better patient care, easier access to data for healthcare professionals, and a more efficient industry as a whole. On the other?
It’s created a lot of confusion where compliance is concerned.
The misconception lies with the EHR itself. With the idea that just because an electronic health record system is compliant, the entire organization is compliant. It’s the sort of thing shifty vendors will try to sell their clients to fool them into a purchase – claiming that because their EHR system is fully compliant, that covers all of the company’s compliance mandates.
Thing is, even if your EHR system is entirely cloud-based, doesn’t mean you’re covered. What you must remember is that HIPAA applies to everything involving Personal Health Information (PHI). That includes phone conversations, messages sent between staff, non-anonymized treatment plans, physical documents, and more.
To be fully HIPAA compliant, you do need a HIPAA compliant EHR system. But you also need to assess the security of everything within your organization – applications, databases, workflows, internal processes, and more. Moreover, it is your responsibility to ensure that any business you work and share data with, be they a vendor or a partner, is fully HIPAA compliant, as well.
If it sounds like an involved, fairly difficult process, that’s because it is. Making the leap from noncompliance to full compliance isn’t something you’ll achieve overnight. Rather, it needs to be a gradual, strategic, deliberate process.
To ensure your success, there are a few actions you should take.
- Designate a HIPAA compliance officer. Ensure they have a firm understanding of HIPAA, and that they have a complete picture of your business, its infrastructure, and its workers.
- Ensure there are clear processes in place for both digital and physical files. These processes should include strong access controls, strict regulations on who can access what information, and clear designation of responsibility for data management. More importantly, make certain these processes themselves comply with HIPAA.
- Perform a full HIPAA risk analysis, identifying and mitigating any potential security flaws you uncover.
- Mandate the use of audit trails which record everything about file access. This provides visibility into how your data is used and ensures you have an additional layer of security in the event of unauthorized access.
- Ensure all workstations and devices are both fully-managed and secure – if a device is compromised, it should be easy for IT to wipe the data on that device.
EHR HIPAA compliance is definitely part of HIPAA compliance. It is not, however, the only thing that’s involved. To be fully compliant, you need to step back and look at the complete picture of your organization, including its partners, its staff, and its infrastructure.
Only then can you give your patients the protection they deserve – the protection that’s required by law.