Despite common knowledge that hybrid systems are worse than either fully paper or electronic records, we continue to see proliferation of models implemented that promote the hybrid record as an extended transition strategy; however, with proper planning, you can avoid entering into a hybrid state.
Determine whether and how you’re vulnerable, as well as whether revising your policies and beefing up your education to specifically address these privacy concerns is enough to satisfy your HIPAA responsibilities and the wants of your staff members.
Chris Apgar, CISSP, and John R. Christiansen, JD, answered questions regarding BA contracts during HCPro’s July 29, 2009, audio conference, “Business Associates and Covered Entities: Adapt Contracts to Comply with New HIPAA Law.” Apgar, president of Apgar & Associates, LLC, in Portland, OR, and Christiansen, founder of Christiansen IT Law in Seattle, provided the following responses to questions posed during the audio conference: