Agree.
gs

-----Original Message-----
From: Cathy Skinkis [mailto:[EMAIL PROTECTED]
Sent: Wednesday, August 27, 2003 7:42 AM
To: WEDI SNIP Security Workgroup List
Cc: [EMAIL PROTECTED]
Subject: RE: HIPAA Security - Unique Access


I would say yes in as far as security is concerned. You need to make sure
that only the people that need to access that information, access that
information. One of the ways to do that is to Audit the users, the times the
system was accessed, etc. Although you are not responsible to account for
disclosures prior to April, 2003, You would still need to account for anyone
that is accessing those old records via this software,(after April, 2003) if
it is for purposes other than TPO.

Hope this makes sense.

Make it a great day!

Cathy Skinkis
ISO
St. Mary's Hospital
Green Bay, WI   

-----Original Message-----
From: Mimi Hart [mailto:[EMAIL PROTECTED]
Sent: Tuesday, August 26, 2003 1:34 PM
To: WEDI SNIP Security Workgroup List
Cc: [EMAIL PROTECTED]; [EMAIL PROTECTED]
Subject: Re: HIPAA Security - Unique Access


I probably sound like I am trying to parse on a thin line, but here goes
(bear with me).

I don't believe that patient's rights under Privacy & Security are
retroactive - that is they can't ask us to run an audit trail or produce
a disclosure log for data that accessed or disclosed before April 14,
2003.

However, if I am buying an application that is ONLY going to contain
data that was PRODUCED before April 14, 2003 (such as microfilm pull-up
software for medical records produced in 1999-2000) must I have the
ability to audit, use unique sign-ins, etc for when that data is
accessed by staff as part of treatment, payment or healthcare
operations? 

Mimi Hart Ó¿Õ*
Research Analyst, HIPAA
Iowa Health System
319-739-2430 (phone)
319-739-2594 (fax)
319-490-0637 (pager)
[EMAIL PROTECTED]

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Moses Cone Health System 
Greensboro, North Carolina 27401

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