tci Medicare Compliance & Reimbursement - 2023 Issue Q4

HIPAA: Don’t Skimp On Sanction Policymaking, Feds Warn

Tip: Ensure employees receive training equivalent to their duties. When a data breach occurs, there’s more to an organization’s mitigation duty than merely retrieving the records and stopping the incident. That’s where a sanction policy comes into play. Your mitigation efforts must extend to the sanctions you levy on staffers who cause inappropriate protected health information (PHI) disclosures under HIPAA, regardless of their intent. Context: According to the HHS Office for Civil Rights (OCR), a sanction policy is “an important tool for supporting accountability and improving cybersecurity and data protection,” the agency maintains in...

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