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  • 1.  3/23 and 11/23...why these are Important!

    Posted 6 days ago
    All right...we now know that the Final Rules related to the NPRM for the Privacy Rule are expected to be published sometime in 3/23.  So two quick and preliminary takeaways and suggestions:

    1. Take advantage of having time to do some preliminary reviews of potentially impacted processes as described in the NPRM, but remember, you want to see those Final Rules to understand what specific changes you may need to actually make; and
    2. Time is on your side, at least for now.  If you take some time to now prepare for what we may get in the Final Rules, it may lessen the sense of needing to move quickly or feeling rushed.
    Remember, if what we read in the NPRM is consistent with the Final Rules...we will have basically 240 days after the publication of the Final Rules to be ready for when the OCR will begin enforcement.  So keep that in mind as we all move together towards where we need to be.  This is why I mentioned November in the Discussion Subject for this posting since November is 8 months from March.

    Note...I understand that Business Associates are not required to comply with the Privacy Rule.  However, I posted this in the HIPAA for Business Associates eGroup as there may be Business Associates that are delegated various processes which will be impacted by the Final Rules.

    Stay tuned!

    Posted: 4:17 AM AZ time

    -------------Frank "Snake Bite Leader" Ruelas--------------
    ► We don't fail unless we quit! ◄
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  • 2.  RE: 3/23 and 11/23...why these are Important!

    Posted 5 days ago
    Thank you for this Frank.  Forgive me for this question, but where did you see that the Final Rule is expected to be published in March?  I'd like to take a look at the source(s) as they sometimes have some good information about the topic as well.

    Lance Smith
    Privacy Officer
    St. Peter's Health Partners
    East Greenbush,NY

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