ONC recently published an updated guide for Privacy and Security of Electronic Health Information.  This episode David and Donna discuss what that guide calls the Seven-Step Approach for Implementing a Security Management Process.


Links


Guide to Privacy and Security of Electronic Health Information


FindHealthcareIT


HIPAAforMSPS.com


Kardon Compliance


Notes


The 7 Steps


Step 1: Lead Your Culture, Select Your Team, and Learn


Assign your officers, make sure they are trained, show compliance is a top down commitment


Step 2: Document Your Process, Findings, and Actions


If you can't prove it then it didn't happen. Document your decisions, plans and activity


Step 3: Review Existing Security of ePHI (Perform Security Risk Analysis)


Review or perform your Security Risk Analysis and current security assessment


Step 4: Develop an Action Plan


The plan needs to address all the things you identified in your assessments, policies, and procedures


Step 5: Manage and Mitigate Risks


This is where your project management skills come into play making sure you have addressed all the risks in your Analysis and new ones aren't showing up


Step 6: Attest for Meaningful Use Security­Related Objective


If you are attesting make sure you have done the previous steps


Step 7: Monitor, Audit, and Update Security on an Ongoing Basis


Remember it isn't a project that has a beginning and ending date