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The HIPAA Security Rule (at 45 C.F.R. §164.308(a)(1)(ii)(A)) requires an initial security risk analysis according to risk analysis guidance issued by HHS/OCR based on NIST standards.
OCR Audit Protocols for Risk Analysis are clear! CMS, as planned, has launched audits of organizations who have attested to Meaningful Use Objectives and Risk Analyses will be audited. Have you completed a bona fide HIPAA Security Risk Analysis?