I always mention
this
in my day-to-day practical work with the
compliance
of an
organization
,
that is
, the head of
compliance
should have a very good knowledge of the
organization
or business in which he undertakes
this
most serious task.
1. Risk assessment. The first action of a chief
compliance
officer is to assess the risks that threaten the medical profession and the operation of the Practice
such
as: a] The protection of the medical information of the patients which is sensitive personal
data
. The principles of confidentiality, integrity and availability should be respected. b] All operational and operational vulnerabilities should be assessed.
For example
, from my personal experience at the Trans-Balkan Medical Center, I know that
this
organization
maintained
security
with key codes and encrypted messages that protect sensitive patient
data
.
2. Meeting with the Board of the Clinic for complete and clear information about the risks, the needs and the costs that must be incurred in order for there to be success in the undertaken project.
3. Program schedule and action plan. a] The urgent points that require the fastest response to avoid any kind of damage, financial or reputational etc. b] Physical and technological safeguards for the protected operation of patients and their
data
,
such
as: Secure physical
access
to areas where
PHI
is stored,
such
as locked filing cabinets, secure
access
to computer systems, and controlled
access
to offices. Ensure that electronic
PHI
(ePHI) is protected through encryption, firewalls, secure email systems, and regular backups. Develop and enforce
policies
and procedures that govern the handling of
PHI
, including
access
control,
data
sharing, and breach reporting.
4. Continuous training of
staff
and senior management.
Staff
Training: Educate all employees on
HIPAA
requirements, emphasizing the importance of confidentiality and
security
of
PHI
. Training should be ongoing and updated regularly. Phishing Awareness: Teach
staff
to recognize and respond to phishing attempts and other cybersecurity threats.
5. Monitor and Audit: Regular Audits: Conduct periodic audits to ensure
compliance
with
HIPAA
policies
and procedures.
This
includes reviewing
access
logs, assessing the effectiveness of
security
measures, and ensuring that all
staff
members adhere to training protocols. Incident Response: Establish a procedure for responding to potential breaches, including a clear reporting process and steps to mitigate damage.
6. Update and Adapt: Policy Review: Regularly review and update
policies
and procedures to keep up with changes in
HIPAA
regulations or in the office's operations. Technology Updates: Ensure that all systems handling
PHI
are updated regularly to protect against new
security
threats.
7. Consulting in Making a Plan a. Legal Counsel: Engage with an attorney specializing in
healthcare
law and
HIPAA
compliance
to ensure that all legal aspects are covered. b. IT and
Security
Experts: Consult with IT professionals who specialize in
healthcare
to ensure that all technical safeguards are correctly implemented and maintained. Consider bringing in a cybersecurity expert to assess and enhance the
security
of electronic
PHI
. c.
Compliance
Officer or Consultant: If the office doesn't have a dedicated
compliance
officer, consider hiring a consultant with expertise in
HIPAA
compliance
to help develop and implement the plan. d.
Healthcare
Staff
: Engage with the office’s
healthcare
providers and administrative
staff
to understand their workflows and how they interact with
PHI
. Their input is crucial for developing practical and effective
policies
. e. Third-Party Vendors: Review contracts with third-party vendors who may have
access
to
PHI
(e.g., billing services, IT providers) to ensure they are
also
HIPAA
-compliant.
Conclusion, with all the above actions, we have the surelly faith that the
organization
aplies all thw prerecusits for HIPPA
compliance
.