HI Tami,
 
When you email notes that it is a "summary of the system requirements for
Part 11 and HIPAA's security rule", does that mean that this summary is from
HSS or another government source, or did some one compile this summary based
upon their understanding of HIPAA requirements for data security? 

Thanks, Tami,
Bill 

  _____  

From: FileMaker Pro Discussions [mailto:[EMAIL PROTECTED] On
Behalf Of Tami Williams
Sent: Friday, December 05, 2008 12:19 PM
To: [email protected]
Subject: Re: need info about FileMaker 9 and HIPPA compliance


Here's a summary of the system requirements for Part 11 and HIPAA's security
rule.

Does this cover everything?  Is everything on this list required?


1. Access control  - unique user identification login system with a method
for identifying and tracking each user; require user-specific log-ins, no
shared logins; define and follow processes which provide access only to
authorized users (human or electronic); deny access to unauthorized users.
(Access Controls, User Authentication, and Password Management)
a. validation
b. granting
c. role-based
d. function-based

2. Contingency Planning/Emergency Access Procedure - Follow reliable backup
procedures, and develop a contingency plan appropriate to address the most
likely emergencies.

3. Audit log, Access reporting, Incident tracking: track who logged in and
when; track data modification-where appropriate and relevant-and system
access, and provide a mechanism for review. (Audit log, Access reporting,
Incident tracking)

4. Data integrity: Create a controlled environment where create, edit, and
delete functionality is limited to authorized users under "proper"
circumstances. (Incorporate Data Integrity via Role- and Function-based
Access Controls, User Authentication, Password Management, and Audit Log)

5. User authentication: The system must be able to validate the unique
identity of each user seeking access-including non-human connections.
(Access Controls and User Authentication)

6. Transmission Security: Protect against unauthorized access during any and
all network transmissions.
(Incorporate Access Controls, Data-level Encryption, Network Encryption via
FileMaker Server, and External Security Measures. )

-----

Are these also "required"?

7. Automatic log-off


8. Encryption/Decryption: All electronic protected health information (ePHI)
must be protected with encryption, but not to the extent that is no longer
accessible. A decryption mechanism must therefore be provided for the
retrieval of encrypted ePHI;  Apply an Encryption/Decryption schema to all
fields containing ePHI.  Encrypt ePHI. You may edit and view ePHI in a
pre-encryption or decrypted state, but do not store unencrypted ePHI.


9. Mechanism to Authenticate ePHI:  system must be able to substantiate that
it has not permitted unauthorized alteration or destruction of ePHI.  Use an
audit trail to prove that only authorized alterations and deletions have
occurred, but the auditing of activity does not prevent unauthorized
activity. A combination of measures must be employed to ensure the failure
of unauthorized attempts to alter or destroy ePHI. (Access Reporting,
Incident Tracking, Access Controls, Auto Log-off, Encryption, User
Authentication, and Password Management)


10. Integrity Controls:  Protect ePHI during transmission (regardless of to
whom) such that modification during transmission will be detected. Utilize
Encryption and Access Controls to protect ePHI, and employ Data
Authentication measures to verify Data Integrity.


And these:

12. Password management


6. User documentation


10. Data authentication



~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
"It's better to burn out than to fade away."

Tami Williams
Creative Computing
Improve, manage and unify data with custom database and web applications.
FileMaker and Lasso specialist.

Tel: 770.457.3221
Fax: 770.454.7419
E-Mail: [EMAIL PROTECTED]
Web: http://www.asktami.com

FileMaker Solutions Alliance Associate | Lasso Professional Alliance Member 

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