John,

I don't think it is necessary to appoint a legal person per say. Since
HIPAA's main focus is the protection of IT this should be right up your
alley.

It would be quite expensive if you had say an attorney handle everything. It
is cheaper to call legal counsel and ask questions about things you are not
sure of. Depending on the size of your company you may have an attorney on
retainer.

Your best bet is to have yourself as the one heading up HIPAA and put
together a committee with the heads of Health insurance area and other
departments you may not know a lot about. My areas of expertise tend to lean
towards physical security and personnel security.. I work with the Director
of Nursing, Administrator, and the lead person in IT. I also use advise from
our field supervisor.

We have a small committee and we hash over things to put things together. It
is nice to have different opinions and perspectives to put a plan together.

JC
Progressive Home Care
Cleveland, Ohio
----- Original Message ----- 
From: "Kuisle, John P." <[EMAIL PROTECTED]>
To: "WEDI SNIP Security Workgroup List" <[EMAIL PROTECTED]>
Sent: Tuesday, September 16, 2003 12:47 PM
Subject: HIPAA Security Official


All,

I was looking for a little feedback on what other companies are doing with
regard to naming a Security Official to comply with the HIPAA Security rule.

As one of our Legal experts and I looked at the duties of that person, many
of them were aligned with my job, so the logical conclusion is that I could
fill the role.  However, since I'm an IT person, fairly low on the food
chain and not really aligned with any particular business area and since the
HIPAA Security Regs are specific to electronic health information, there was
some question about whether this responsibility should be given to someone
from our Health Insurance area or a Legal person.

John Kuisle
IS Supervisor - Security and Business Recovery
Federated Mutual Insurance
507-455-5477
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