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We were trying to deal with this issue and determined that the only way
to protect electronic PHI, as 164.530 of the Privacy Rule requires is to
either encrypt emails or not send emails
containing PHI. Out of curiosity (because I'd love to find a way around this) If
you are not encrypting, how are you meeting the privacy regulations requirement
to protect electronic PHI?
Deborah
Campbell
The
Privacy rule does not call for encryption. Having said this, at the very least
I would inventory those instances and inform the c.e. so that both of you
can start working on secure transmission methods. Obviously the sooner you
address this the better, but I would say you'd have 2 years to get there if
you need to, as far as compliance is concerned.
The caveat goes to what would be
considered "reasonable"
a.
I would appreciate any suggestions on how a
business associate should address the receipt of PHI from a covered entity
that has been sent across an open network (without encryption) after the
Privacy Rule is enforceable.
Thank you.
Marcus McCrory
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