Wednesday, 09 May 2018 08:42

Are you prepared? Design an emergency prepardness plan!

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At the recent annual conference of the Association of Professional Developmental Disability Administrators (APDDA), we had the pleasure of hearing from administrators from facilities in Corpus Christi and San Antonio, Texas and Miami, Florida who spoke about their experiences preparing for and recovering from Hurricane Harvey and Hurricane Irma last fall. Part of building an emergency preparedness plan includes making provisions to meet the needs of residents with disabilities in the event of an evacuation.

But! Even in an emergency preparedness plan, a resident's health information is still protected by the HIPAA Privacy Rule.

Check it out! The Department of Health and Human Services offers a great interactive tool, The HIPAA Privacy Decision Tool, that through a series of questions helps you determine how the HIPAA Privacy Rule would apply in specific emergency situations (it's available as a flowchart, too!). Other emergency preparedness resources are also available through the HHS site.

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10 Step HIPAA Plan

  • Step 1: Confirm you are a covered entity +

    What's Inside:
    Lists of who is generally covered and who is not, plus contact for inquiries.
  • Step 2: Provide leadership +

    What's Inside:
    • 7-page HIPAA basics
    • 62-page guide to security and privacy of ePHI
    • Compliance Charter Template
  • Step 3: Document processes, findings, and actions +

    What's Inside:
    Templates for Security Policies and Procedures
  • Step 4: Conduct a security risk analysis +

    What's Inside:
    INTRODUCTORY:
    • Guides
    • Short videos
    • Interactive quizzes on risk assessment and contingency preparation
    • 10 common myths

    ADVANCED:
    Interactive tutorial – 156 questions with fill-able PDFs for Windows or iPad. All material from federal sources.
  • Step 5: Develop an action plan +

    What's Inside:
    INTRODUCTORY:
    • 11-page overview on ePHI for small practices
    • 4-page Q&A addresses email with patients
    • Checklists

    ADVANCED:
    Toolkit on 45 implementation specifications
  • Step 6: Manage and mitigate risks +

    What's Inside:
    • Overview of expectations
    • Annual Work Plan Template
  • Step 7: Prevent breaches +

    What's Inside:
    • Form for reporting brief notification
    • Links to details on the notification process and what constitutes a breach.
    • Suite of Training Materials
  • Step 8: Communicate with patients +

    What's Inside:
    FOR ALL:
    Privacy notice templates to help achieve meaningful consent, in English & Spanish.

    INTRODUCTORY:
    Professionals' guide covering 2013 updates on communications.

    ADVANCED:
    Electronic toolkit with patient education and meaningful consent sample materials.
  • Step 9: Update or execute Business Associate Agreements (BAAs) +

    What's Inside:
    • Sample Business Associate Agreement (BAA) provisions
    • Suite of BA Management Tools
  • Step 10: Attest to Compliance with Security Objectives +

    What's Inside:
    INTRODUCTORY:
    • Tip sheets
    • Short videos
    • Overviews

    ADVANCED:
    • 94-page guide on the EHR incentive program
    • Beginners' toolkit on reporting to the government

    All from federal sources.
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