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Implementing an Audit Program for HIPAA Compliance

Implementing an Implementing an Audit Program for Audit Program for HIPAA ComplianceHIPAA ComplianceMike LynchMike LynchHIPAA Summit WestHIPAA Summit WestMarch 14, 2002 March 14, 2002 Page 2 Why Audit ?Both the Security NPRM and the Final Privacy rule require access on a minimum need-to-know basis. The entity must be able to demonstrate that their system(s) for accessing information meets these standards, and that the entity monitors access to verify that unauthorized access is not 3 Why Audit ?Section Responsibilities of Covered EntitiesA covered entity must keep such records and submit such Compliance reports, in such time and manner and containing such information, necessary to enable the Secretary to ascertain whether the covered entity has complied or is complying with the applicable requirements of part 160 and the applicable standards, requirements, and implementation specifications of Subpart E of Part 164.

Page 6 A Covered Entity Must Keep an Audit Trail of Disclosures: uWhere authorization is required, and whether initiated by the covered entity or by the individual (i.e. for purposes other than treatment, payment or healthcare

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