That is what your gap analysis is supposed to identify....your policy gaps.
You document what you are doing today, what your policies are, what reports
are created and sent, who sends information to you and how etc...then you
compare that to the rule.  The areas where you are not following the rule
become gaps in policy and they will need remediation.

There are several HIPAA policy templates being offered in the marketplace
and I recommend you investigate the source to be sure they know what they
are doing.  I know of three sources today and our attorney will be offering
some which makes four sources. 

Catherine Lohmeier
HIPAA Project Consultant
XANTUS Healthplan of Tennessee

-----Original Message-----
From: Spencer Hall [mailto:[EMAIL PROTECTED]]
Sent: Monday, September 23, 2002 11:51 PM
To: [EMAIL PROTECTED]; SVRTR#c#[EMAIL PROTECTED];
[EMAIL PROTECTED]
Subject: Re: RE: Policies and Procedures


While we are also interested in looking at sample policies and procedures,
of more value would be how members are identifying what polices & procedures
needs to be re-written or written to be in compliance with the Privacy and
Security regulations.



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