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HITECH Modifications to HIPAA Rule

From: Freeman, Marilyn (IHS/CAL)
Sent: Wednesday, September 04, 2013 4:39 PM
Subject: HITECH Modifications to HIPAA Rule

I have attached a document (PDF file) which summarizes HITECH modifications to HIPAA. I realize that I have made this information available previously so you may well be aware.  The rule was published in January of this year, became effective in March, and compliance is required by September 23, 2013. 

Note that the changes will require modification of your HIPAA notice of privacy practices as well as business associate agreements. 

HIPAA Notice of Privacy Practices (NPP):  Please note that your clinic must make the HIPAA notice of privacy practices available to patients in three ways:

  1. When they first receive care
  2. By visible posting in public area
  3. Through visible posting on clinic website (if one is in place)

IHS will release an updated HIPAA notice of privacy practices (NPP) soon.  I will distribute the NPP and other revised HIPAA forms once I receive them. 

Business Associate Agreements:  New and/or revised business associate agreements must be compliant beginning September 23, 2013.  Existing business associate agreements must be made compliant by September 2014.

There are other changes as well…

Warm Regards

Marilyn Freeman, RHIA

Clinical Application Coordinator
California Area Indian Health Service