HIPAA — Countdown to New Regulations


The new HIPAA regulations become effective on September 23, 2013. Many health care providers have been focused on revising business associate agreements and getting them signed up. Keep in mind that new business associate agreements are only one of several changes mandated under the HIPAA Omnibus Rule. If you haven’t done so already, now is the time to take the other actions necessary to comply by the deadline.

As a health care provider, your “to do” checklist should include the following:

  1. Update policies:
    • Breach Notification
    • Notice of Privacy Practices
    • Right to Request Restrictions on Disclosures of PHI
    • Right to Access
    • Uses and Disclosures: deceased individuals; immunization records/schools; marketing; fundraising; sale of PHI
    • Authorizations for research purposes
    • Business Associates and Subcontractors
  2. Update related forms and documents, including:
    • Notice of Privacy Practices
    • Business Associate Agreement
  3. Enter into new business associate agreements
  4. Post and distribute new Notice of Privacy Practices
  5. Finally, if you haven’t thought about HIPAA in awhile:
    • Confirm you have HIPAA security policies addressing safeguards for electronic PHI
    • Conduct a security risk assessment
    • Confirm that you have a HIPAA breach notification policy   


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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