At 5:08 AM +0000 1/23/03, The Long and Winding Road wrote:
>Howard, do you have an opinion you would care to share publicly regarding
>organizations such as TruSecure and their HIPAA initiatives? Worth
>considering? Studying?

All I know about them is their website, where there's an article 
describing their teaming with Corporate Compliance Services to 
identify "gaps."

Let me simply say this. I know of no security technique that's unique 
to HIPAA. Encryption is encryption, identification is identification, 
etc.  The challenges in HIPAA compliance include:
     1) When do you need to comply with OTHER healthcare privacy and security
        requirements NOT in HIPAA, such as DEA, Medicare, CLIA, 21CFR11,
        FDA postmarketing surveillance, etc.?
     2) How do you integrate these into a medical culture? It's far easier
        to herd cats than to tell surgeons what to do.
     3) Can you create the necessary design and implementation  paper trail
        to show due diligence to soft requirements, should legal problems
        arise? Can you demonstrate risk-benefit?

In other words, a lot of the study involved is not particularly 
security -- you probably know enough -- but of the medical 
environment, both its culture and regulations. How do you resolve 
conflicts between different sets of regulations, such as HIPAA 
specifying "emergency access" as a requirement but DEA requiring 
biometrics?




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