Q: As part of the audit controls policy at my organization, we hired an external security vendor to collect and review logs from several critical servers. The vendor creates tickets for our IT staff when a potential incident is discovered during the daily log review. This supplements our own activity reviews of internally generated reports, and the vendor then uses them for its own review. Our internal staff never sees the reports the vendor uses for its review. Do the reports the vendor uses fall under the HIPAA requirement for retaining logs for six years? Should we compel the vendor to retain these reports?
There are many misconceptions about HIPAA throughout the healthcare industry. In particular, business associates (BA) who provide cloud services to covered entities (CE) often have the misconception that they do not need to be concerned with HIPAA if they are compliant with the Payment Card Industry Data Security Standard (PCI-DSS). BAs with this school of thought should be prepared to get their checkbooks out when the Office for Civil Rights (OCR) comes calling.
The Office for Civil Rights (OCR) announced December 8, 2014 that it fined an Alaska behavioral health service $150,000 for potential HIPAA violations. OCR entered into a resolution agreement with Anchorage Community Mental Health Services (ACMHS), a nonprofit behavioral healthcare service, per the announcement (see www.hhs.gov/ocr/privacy/hipaa/enforcement/examples/acmhs/amchs-capsettle...).
Beginning January 1, 2015, physicians will no longer need to provide certification for an inpatient admission unless the admission is expected to last for at least 20 days or the case is an outlier.
In December 2014, CMS posted a document on its Advisory Panel on Hospital Outpatient Payment (HOP Panel) website outlining the hospital outpatient therapeutic services that were recently evaluated for a change in supervision levels. The three-page document contains a chart that includes the HCPCS code, the level of supervision required for coverage, and the effective dates of the changes for various services.
