Editor's note: The following is adapted from the HCPro book The HIPAA Omnibus Rule: A Compliance Guide for Covered Entities and Business Associates, by Kate Borten, CISSP, CISM, president of The Marblehead Group in Marblehead, Mass. To learn more about the book, go to www.hcmarketplace.com.
There is some common ground in the corrective action plans (CAP) that OCR has imposed on healthcare organizations it has investigated for HIPAA privacy and security deficiencies.
As an HIM director, you are responsible for the integrity of your patients' records-even when your hospital shuts down certain wings of the facility or closes its doors entirely.