Key Factors to Write HIPAA Compliance Policies
Overview:
The webinar will explain the process for covered entities and business associates to use to draft, adopt, and implement HIPAA compliance policies. The webinar will begin with a discussion of how to decide, using a gap analysis and a risk analysis, what policies the organization needs, including required, addressable, and other policies. Then, the webinar will cover writing a policy. Writing a policy is easier than one may think. It is a three-step process: researching, drafting, and revising.
This webinar will teach you to ask questions, solicit help, collect samples, keep the principles of substance, organization, coherence, style, and correctness in mind while you are drafting, send your draft out for review, incorporate comments, implement the policy, and repeat as necessary. The prospect of developing and writing perhaps as many as 70 policies to attain HIPAA compliance may still seem daunting, but this webinar will teach you how to make a checklist, take it step by step, and enlist the help of others when you need it.
Why should you attend: The majority of the DHHS civil money penalties and settlements in lieu thereof involve, sometimes with other violations, failure to perform a written risk analysis, failure to develop required policies, and failure to conduct adequate HIPAA training. These penalties usually are in the seven-figure range.
Failure to conduct a written risk analysis, adopt required policies, or conduct required training qualifies as "willful neglect," which carries the highest civil money penalty ("CMP") and which penalty cannot be waived by DHHS as can violations due to a reasonable cause. DHHS entered into a settlement with Massachusetts General Hospital for $1 million for a breach involving leaving paper PHI records on a subway. The sanction was because Massachusetts General had not trained its workforce on proper security for PHI taken offsite and did not have a work-at-home policy. Significantly, HIPAA does not even mention working at home, much less specifically require such a policy.
Areas Covered in the Session:
- Preliminaries
- Learn how to decide which policies to write and adopt, using gap analysis and risk analysis
- Learn which policies are required and which are addressable
- Learn about other policies that your organization may need that are not mentioned in the HIPAA regulations but that organizations have nonetheless been fined for not having
- Researching
- Ask questions. Learn why you need to nail down the answers to at least 12 questions before you try to write a policy and how to do so
- Solicit help. Learn whom to solicit help from both within and outside your organization and when and why and how
- Collect samples. Learn what samples to collect and from whom
- Drafting
- Substance. Learn what substance means and how to achieve it
- Organization. Learn how to draft a clear beginning, a clear middle, and a clear end
- Coherence. Learn how to connect your ideas so that readers will not have to wonder where something came from or why
- Style. Learn how to write for your target audience as simply and clearly as possible
- Correctness. Learn how to get rid of the static in your writing
- Revising
- Review. Learn whom to contact to review your drafts
- Incorporate. Learn how to resolve disputes and incorporate changes
- Implement. Learn how to lay out a plan for implementation of the policy, including publishing, distribution, implementing (and perhaps even training the workforce on the policy), and schedule for annual review and revision, if necessary
Who Will Benefit:
- Compliance Director
- CEO
- CFO
- Privacy Officer
- Security Officer
- Information Systems Manager
- HIPAA Officer
- Chief Information Officer
- Health Information Manager
- Healthcare Counsel/lawyer
- Office Manager
- Contracts Manager
