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Three Steps to Automate Compliance for 
Healthcare Organizations 
Dana Simberkoff, JD, CIPP/US 
Chief Compliance and Risk Officer, AvePoint 
Marc Dreyfus, CIPP/US, CIPP/T 
Director, Risk Management & Compliance, AvePoint 
Accessible content is available upon request.
• State of IT Compliance 
• HIPAA, HITECH -Why worry? 
• Assessment: Knowing is Half the Battle 
• Three Steps to Automate Compliance: Say it, Do it, Prove it 
• Getting to Yes: Privacy & Security by Design
State of IT Compliance
Trust In: 
 Individuals 
 Organizations 
 Policies 
 Procedures 
 Process 
 Technology 
 Transactions
Everyone is a contributor
How do we balance the business benefit of the free flow of information with the 
risk of inappropriate access and disclosure?
Broad application 
… to doctors, hospitals, pharmacies, medical billing services, health care plans, HMOs, and business associates of 
these entities such as their accountants and attorneys 
Applies to all records 
Requires that all records regardless of format be managed as part of the organization’s official records 
management program 
Carries hefty penalties 
Medical fraud has increased nearly 20 percent in the past year, affecting an estimated 1.84 million American adults 
and costing victims $12.3 billion in out-of-pocket medical expenditures.
Openness & 
transparency 
Ensure all data sources link to privacy policies 
Collection, use & 
disclosure limitation 
Secure methods used to collect PHI through 
websites and web applications 
Safeguards 
Monitor, notify, and act when PHI is stored 
inappropriately 
Accountability 
Multi-layer reporting to deliver visibility into HIPAA 
compliance status 
Individual choice 
Allow for review of privacy policy and opt-out prior 
to submitting PHI 
Correction 
Create an accessible, protected manner for 
disputing accuracy of information through secure 
web-enabled applications
Measurement and Verification are key components to a holistic system 
• Policy 
• Training
Measurement and Verification are key components to a holistic system 
• Policy 
• Training 
• Technology
Assessment: Knowing is Half the Battle
• What kind of data is 
stored in your 
information and 
collaboration gateways 
and why? 
• How business users 
within your organization 
are utilizing the IT 
systems that hold 
information that may be 
at risk. 
File System 
Cloud 
Social 
SharePoint
Three Steps for Compliance Automation
Say what 
you are 
going to do 
Do it… 
Prove that 
you did it
Say It Do It 
1 2 3 4 5 
Prove It 
Incident Tracking 
Assess Prioritize 
Ongoing 
Monitoring 
7 
Incident 
Management 
6 
8
Say It: Discover Data & Define Enforceable Compliance Policies
Develop a service level agreement 
among your compliance officers, your IT 
team, and the business before you 
implement a compliance plan. 
It’s important to understand: 
• What kinds of data your business handles and 
uses 
• How your co-workers are using it for their day-to-day 
jobs 
• Why and how they need to handle protected data 
in the course of their work
What are you trying to 
protect and from whom? 
Name 
Address 
Important dates 
Telephone & fax numbers 
Email address 
Social Security number 
Medical record number 
Health plan beneficiary number 
Account number 
Certificate/license number 
Vehicle/device serial numbers
Do It: Take Action on Risk-Defined Content and Systems to Ensure 
Compliance
Create common-sense 
policies, rules, and IT controls 
Implement transparent and 
non-transparent controls to IT 
environments 
Automate the process of 
regulated content protection
Trust your end users 
to appropriately 
identify and classify 
sensitive data they are 
handling and/or 
creating, but verify 
that they are doing so 
properly.
• Make it easier for your employees to do the right 
thing than the wrong thing 
• Create a transparent security organization to 
discourage employees from working around security 
“Culture eats strategy for lunch!”
Prove It: Monitor and Report on Compliance Initiatives
Compliance Improvement 
Measurement Over Time 
Compliance Activity 
Tracking
Getting to Yes: Privacy & Security by Design
Business 
Users 
IT 
Colleagues
Download our free privacy impact 
assessment tool 
privacyassociation.org/resources/apia 
Learn more about Compliance Guardian 
avepoint.com/compliance-guardian 
Sign up for a free consultation 
pages.avepoint.com/compliance-consultation 
Article: Automation key to successful 
policy implementation 
ow.ly/ENB13
Q & A

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3 Steps to Automate Compliance for Healthcare Organizations

  • 1. Three Steps to Automate Compliance for Healthcare Organizations Dana Simberkoff, JD, CIPP/US Chief Compliance and Risk Officer, AvePoint Marc Dreyfus, CIPP/US, CIPP/T Director, Risk Management & Compliance, AvePoint Accessible content is available upon request.
  • 2. • State of IT Compliance • HIPAA, HITECH -Why worry? • Assessment: Knowing is Half the Battle • Three Steps to Automate Compliance: Say it, Do it, Prove it • Getting to Yes: Privacy & Security by Design
  • 3. State of IT Compliance
  • 4. Trust In:  Individuals  Organizations  Policies  Procedures  Process  Technology  Transactions
  • 5. Everyone is a contributor
  • 6. How do we balance the business benefit of the free flow of information with the risk of inappropriate access and disclosure?
  • 7.
  • 8. Broad application … to doctors, hospitals, pharmacies, medical billing services, health care plans, HMOs, and business associates of these entities such as their accountants and attorneys Applies to all records Requires that all records regardless of format be managed as part of the organization’s official records management program Carries hefty penalties Medical fraud has increased nearly 20 percent in the past year, affecting an estimated 1.84 million American adults and costing victims $12.3 billion in out-of-pocket medical expenditures.
  • 9. Openness & transparency Ensure all data sources link to privacy policies Collection, use & disclosure limitation Secure methods used to collect PHI through websites and web applications Safeguards Monitor, notify, and act when PHI is stored inappropriately Accountability Multi-layer reporting to deliver visibility into HIPAA compliance status Individual choice Allow for review of privacy policy and opt-out prior to submitting PHI Correction Create an accessible, protected manner for disputing accuracy of information through secure web-enabled applications
  • 10. Measurement and Verification are key components to a holistic system • Policy • Training
  • 11. Measurement and Verification are key components to a holistic system • Policy • Training • Technology
  • 12. Assessment: Knowing is Half the Battle
  • 13. • What kind of data is stored in your information and collaboration gateways and why? • How business users within your organization are utilizing the IT systems that hold information that may be at risk. File System Cloud Social SharePoint
  • 14.
  • 15. Three Steps for Compliance Automation
  • 16. Say what you are going to do Do it… Prove that you did it
  • 17. Say It Do It 1 2 3 4 5 Prove It Incident Tracking Assess Prioritize Ongoing Monitoring 7 Incident Management 6 8
  • 18.
  • 19.
  • 20. Say It: Discover Data & Define Enforceable Compliance Policies
  • 21. Develop a service level agreement among your compliance officers, your IT team, and the business before you implement a compliance plan. It’s important to understand: • What kinds of data your business handles and uses • How your co-workers are using it for their day-to-day jobs • Why and how they need to handle protected data in the course of their work
  • 22.
  • 23. What are you trying to protect and from whom? Name Address Important dates Telephone & fax numbers Email address Social Security number Medical record number Health plan beneficiary number Account number Certificate/license number Vehicle/device serial numbers
  • 24.
  • 25.
  • 26.
  • 27. Do It: Take Action on Risk-Defined Content and Systems to Ensure Compliance
  • 28. Create common-sense policies, rules, and IT controls Implement transparent and non-transparent controls to IT environments Automate the process of regulated content protection
  • 29. Trust your end users to appropriately identify and classify sensitive data they are handling and/or creating, but verify that they are doing so properly.
  • 30.
  • 31. • Make it easier for your employees to do the right thing than the wrong thing • Create a transparent security organization to discourage employees from working around security “Culture eats strategy for lunch!”
  • 32.
  • 33. Prove It: Monitor and Report on Compliance Initiatives
  • 34. Compliance Improvement Measurement Over Time Compliance Activity Tracking
  • 35.
  • 36.
  • 37. Getting to Yes: Privacy & Security by Design
  • 38. Business Users IT Colleagues
  • 39. Download our free privacy impact assessment tool privacyassociation.org/resources/apia Learn more about Compliance Guardian avepoint.com/compliance-guardian Sign up for a free consultation pages.avepoint.com/compliance-consultation Article: Automation key to successful policy implementation ow.ly/ENB13
  • 40. Q & A