I agree. I don't believe that a technical firewall is necessary.
Jon
Jonathan B. Peck, Counsel
CIGNA HealthCare Law
860.226.6558/ 8.572.6558(Network)
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> -----Original Message-----
> From: Kevin Fairlie [SMTP:[EMAIL PROTECTED]]
> Sent: Friday, August 09, 2002 4:07 PM
> To: [EMAIL PROTECTED]
> Subject: Questions on firewalls
>
>
> I would just add to this discussion that there are times in the Privacy
> Rule
> that the term "firewall" is used when the drafters clearly are not
> referring
> to what is normally thought of as a "firewall" i.e. a piece of computer
> equipment. This is especially true in the text surrounding requirements
> for
> group health plans.
> For instance, in the Preamble discussion of group health plans, Fed. Reg.
> pg. 82508, it states that plan documents must be amended to among other
> things: "provide adequate 'firewalls' to: identify the employees or
> classes
> of employees who will have access to protected health information;
> restrict
> access solely to the employees identified and only for the functions
> performed on behalf of the group health plan; and provide a mechanism for
> resolving issues of noncompliance." One of the concerns in the group
> health
> plan context is safeguarding PHI from the employer so that it is not used
> improperly i.e. employment decisions. Therefore they want certain barriers
> or "firewalls" set up between the group health plan and the employer. In
> this sense, "firewall" goes beyond the usual technical computer aspect.
>
> Kevin Fairlie
> Diekemper, Hammond, Shinners, Turcotte and Larrew, P.C.
> 7730 Carondelet, Suite 200
> St. Louis, MO 63105
> Phone: (314) 727-1015
> Fax: (314) 727-6804
>
>
>
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