What You Need to Know and Do to Comply with HIPAA A Health Plan Perspective

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What You Need to Know and Do to Comply with
HIPAAA Health Plan Perspective

• Tom Wilder
• Executive Director
• Private Market Regulation
• American Association of Health Plans

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A Step-By-Step Guide for HIPAA Compliance
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Step One Find all of your PHI.
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Step One Find all of your PHI.

• Assume everything is covered by the rule!
• Identify all of the ways you use PHI.
• Identify all of the ways you disclose PHI.
• Identify all of the people you share PHI with.
• Identify all of the places you store or maintain
  PHI.

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Step Two Develop Policies and Procedures
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Step Two Develop Policies and Procedures

• Determine who you can share PHI with and how that
  can be done under the rule.
• Apply the rule to all uses and disclosures of
  PHI.
• Draft policies and procedures to govern uses and
  disclosures.
• Train your workforce.
• Include audit/enforcement program.

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Step Three Respect your members rights.
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Step Three Respect your members rights.

• Right to receive a notice of privacy practices.
• Right to an accounting of uses and disclosures.
• Right to review their PHI.
• Right to request a correction.
• Right to request disclosure restrictions.

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Other Key Issues
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Other Issues Reach out to your business partners.
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Other Issues Preemption
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Other Issues Beware of consultants.
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