New Risk Analysis Policy Posted in Premium Member Section

First, thanks to the Premium Member who suggested that we clearly identify new content on the Premium Member section of the website. We always welcome suggestions as to how to improve the website to make it more helpful to you. We certainly want to be user friendly and not user surly. So look for the new “New” symbol.

Second, I posted a new policy on the Premium Member section of the website, and it’s an important one. Because Blue Cross Blue Shield of Tennessee was recently fined $1.5 million for theft of computer equipment containing protected health information (“PHI”) largely because they had failed to update their risk analysis when they changed storage locations for the equipment as discussed in my post on March 16, 2012, I wrote a Risk Analysis Policy. I have been ranting about the importance of risk analysis for more than a decade, but for some reason had never written a policy requiring risk analysis. But now I have. Consider whether your covered entity or business associate should adopt it.

Third, two more chapters of HIPAA Hysteria are posted on the Premium Member section. Note that Chapter 11 fictionalizes an actual meeting of the HIPAA Risk Analysis Team of the hospital where the novel is set. Although I would love for you to get so anxious to get the rest of the story that you buy the book so that you don’t have to wait for forthcoming chapters, we do want to make the Premium Membership valuable, and if you are patient, you can eventually get all of the novel for free! Maybe by the time all 48 chapters have been posted (at the rate of 2 new chapters a month), I will have finished the sequel, “HITECH Hysteria,” about acquiring an electronic medical record and an OIG complaint investigation.

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