Basic information regarding the changes in HIPAA that will become effective in Mar 2013. This presentation is designed as an introduction to Business Associates.
Importance of Following HITECH Compliance Guidelines Aegify Inc.
HITECH is an ungraded and improvised version of HIPAA (Health Insurance Portability and Accountability Act) that was implementes in 1996. Since then, most healthcare institutions have been adhering to it.
This document discusses the HIPAA Omnibus Rule and its purposes of strengthening HIPAA privacy and security requirements, adopting changes to enforcement rules, modifying breach notification standards, and conforming HIPAA with GINA. Key dates and laws are outlined, including effective dates for the final rule. Common HIPAA violations and most common violators are listed. Examples of HIPAA enforcement actions and associated penalties are provided. Major steps covered entities should take to comply with the final rule are identified.
Connectria provides HIPAA Compliant Hosting for customers in the healthcare and dental industry or anyone who must comply with the HIPAA and HITECH Act security standards surrounding the storage of Protected Health Information (PHI). Our services include:
c
-HIPAA Cloud Hosting
-HIPAA Managed Hosting (Dedicated Server Hosting)
-HIPAA Hybrid Hosting (a combination of Cloud Hosting and Dedicated Server Hosting)
100% HIPAA Compliant & Business Associates Agreement (BAA) Friendly:
Our world-class data centers and hosting services successfully undergo independent 3rd party HIPAA assessments to demonstrate our 100% HIPAA compliance, allowing our many healthcare and dental customers to satisfy their HIPAA security obligations. Connectria also provides hosting for many SaaS providers requiring HIPAA compliance, as well as organizations looking for HIPAA Compliant Cloud Storage. We are also Business Associates Agreement (BAA) friendly, and routinely enter into Business Associates Agreements with our customers.
The Health Insurance Portability and Accountability Act (HIPAA) of 1996 established national standards for electronic healthcare transactions and identifiers. The HITECH Act modernized and strengthened HIPAA's privacy and security provisions due to increased data breaches. Under HIPAA, a breach is defined as the unauthorized acquisition, access, use or disclosure of unsecured patient health information. HIPAA fines for noncompliance can be up to $100 per violation with a yearly maximum of $25,000, while willful violations carry stiffer penalties including imprisonment.
This webinar will describe changes to HIPAA privacy and security regulations that are now in effect, and how covered entities need to update related policies and procedures to ensure compliance. It will review the new regulations and their effects on usual practices. The webinar will discuss what policy changes are needed and how, and what documentation needs to be available in the event of an audit. It is aimed at compliance professionals, healthcare executives and managers, and will benefit all those involved in ensuring HIPAA compliance. The instructor has nearly 30 years of experience in healthcare IT, compliance, and policy work.
The Optometric Protector Plan is able to assist you in meeting the terms of these new regulations. Through our partnership with Beazley Insurance, our program provides a Cyber liability policy that complies with the HIPAA / HITECH laws in the event of a data breach.
The document discusses the importance of HIPAA compliance for businesses that handle medical records. It notes that HIPAA was passed in 1996 and enhanced in 2009 to increase protections for sensitive health information. Businesses found violating HIPAA can face fines between $100 to $50,000 per violation and up to $1.5 million annually. The document emphasizes that HIPAA compliance is crucial to appropriately protecting patient information and ensuring only authorized individuals can access records.
The Summary Guide to Compliance with the Kenya Data Protection Law Owako Rodah
The Data Protection Act 2019, was enacted on November 8th, 2019, ushering a new era of accountability and responsibility with regard to processing of personal data and information. Naturally, there has been a resurrection of the chatter around data protection in increasingly data-driven social and economic settings. The question on everyone’s mind being what does this mean for me?
Importance of Following HITECH Compliance Guidelines Aegify Inc.
HITECH is an ungraded and improvised version of HIPAA (Health Insurance Portability and Accountability Act) that was implementes in 1996. Since then, most healthcare institutions have been adhering to it.
This document discusses the HIPAA Omnibus Rule and its purposes of strengthening HIPAA privacy and security requirements, adopting changes to enforcement rules, modifying breach notification standards, and conforming HIPAA with GINA. Key dates and laws are outlined, including effective dates for the final rule. Common HIPAA violations and most common violators are listed. Examples of HIPAA enforcement actions and associated penalties are provided. Major steps covered entities should take to comply with the final rule are identified.
Connectria provides HIPAA Compliant Hosting for customers in the healthcare and dental industry or anyone who must comply with the HIPAA and HITECH Act security standards surrounding the storage of Protected Health Information (PHI). Our services include:
c
-HIPAA Cloud Hosting
-HIPAA Managed Hosting (Dedicated Server Hosting)
-HIPAA Hybrid Hosting (a combination of Cloud Hosting and Dedicated Server Hosting)
100% HIPAA Compliant & Business Associates Agreement (BAA) Friendly:
Our world-class data centers and hosting services successfully undergo independent 3rd party HIPAA assessments to demonstrate our 100% HIPAA compliance, allowing our many healthcare and dental customers to satisfy their HIPAA security obligations. Connectria also provides hosting for many SaaS providers requiring HIPAA compliance, as well as organizations looking for HIPAA Compliant Cloud Storage. We are also Business Associates Agreement (BAA) friendly, and routinely enter into Business Associates Agreements with our customers.
The Health Insurance Portability and Accountability Act (HIPAA) of 1996 established national standards for electronic healthcare transactions and identifiers. The HITECH Act modernized and strengthened HIPAA's privacy and security provisions due to increased data breaches. Under HIPAA, a breach is defined as the unauthorized acquisition, access, use or disclosure of unsecured patient health information. HIPAA fines for noncompliance can be up to $100 per violation with a yearly maximum of $25,000, while willful violations carry stiffer penalties including imprisonment.
This webinar will describe changes to HIPAA privacy and security regulations that are now in effect, and how covered entities need to update related policies and procedures to ensure compliance. It will review the new regulations and their effects on usual practices. The webinar will discuss what policy changes are needed and how, and what documentation needs to be available in the event of an audit. It is aimed at compliance professionals, healthcare executives and managers, and will benefit all those involved in ensuring HIPAA compliance. The instructor has nearly 30 years of experience in healthcare IT, compliance, and policy work.
The Optometric Protector Plan is able to assist you in meeting the terms of these new regulations. Through our partnership with Beazley Insurance, our program provides a Cyber liability policy that complies with the HIPAA / HITECH laws in the event of a data breach.
The document discusses the importance of HIPAA compliance for businesses that handle medical records. It notes that HIPAA was passed in 1996 and enhanced in 2009 to increase protections for sensitive health information. Businesses found violating HIPAA can face fines between $100 to $50,000 per violation and up to $1.5 million annually. The document emphasizes that HIPAA compliance is crucial to appropriately protecting patient information and ensuring only authorized individuals can access records.
The Summary Guide to Compliance with the Kenya Data Protection Law Owako Rodah
The Data Protection Act 2019, was enacted on November 8th, 2019, ushering a new era of accountability and responsibility with regard to processing of personal data and information. Naturally, there has been a resurrection of the chatter around data protection in increasingly data-driven social and economic settings. The question on everyone’s mind being what does this mean for me?
Training innovations information governance slideshare 2015Patrick Doyle
What you will learn in this training:
Principles of Information Governance and their application to health and social care organisations
Accessing Information Governance resources including national legislation, guidance and local policies & procedures
Health and social care organisations’ responsibilities
Protection of an individual’s confidentiality and the Caldicott Principles
How to practice and promote a confidential service
Principles of ensuring and maintaining good client records
Recognising / responding to Freedom of Information requests
Keeping Information Secure
Infographic describing the rising number of FINRA and SEC disciplinary actions and fines. It also informs customers about how EAI Information Systems can help companies be compliant and survive audits.
The document discusses the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule and how it protects personal health information. It defines protected health information and outlines requirements for covered entities to implement safeguards, limit disclosures, have contracts with business associates, and provide training to employees on protecting patient privacy and health information. Covered entities must implement administrative, physical and technical safeguards and have procedures in place to limit access to health information.
The document summarizes the key aspects of the HIPAA Privacy Rule. It explains that the rule protects personal health information, gives patients access to their medical records, and protects medical information. Covered entities like healthcare providers and health plans must comply. Protected health information includes information about a patient's health, treatment, and payments. Covered entities must get authorization to disclose certain information like mental health notes or for marketing. Entities must notify patients of their privacy rights and document receipt of the notice. Failure to comply with HIPAA can result in civil penalties up to $25,000 per violation or criminal penalties up to $250,000 for willful offenses.
This document discusses emerging legal trends in cyber insurance. It notes that privacy and data security compliance obligations are increasing in the US, Canada, EU and other countries. Proposed legislation in these regions would strengthen data breach notification laws and privacy regulations. The document also summarizes the types of coverage provided by cyber insurance policies, including third-party liability and first-party coverage. It reviews market trends in cyber insurance premiums and who is buying policies. Tips are provided for selecting a policy, such as ensuring adequate limits and sublimits, and watching for consent and panel requirements that could impact claims handling.
Business associate policy and procedure 10Tara Kresge
This document outlines Ophthalmic Associates of Fort Washington's business associate policy and procedures. It states that the practice will establish business associate agreements with any organization that handles electronic protected health information on its behalf or provides certain services to ensure this information is appropriately safeguarded. The security officer will determine which organizations are considered business associates and require written contracts with them that require reasonable safeguards and security incident notification. Examples of business associates include billing companies, software vendors, transcription services, and medical record storage companies.
The HIPAA Privacy Rule protects individuals' personal health information by setting rules and limits on who can access and receive the information. It provides federal protections for health information held by covered entities and gives patients rights over their data. The HIPAA Security Rule establishes technical and physical safeguards for securing electronic protected health information that covered entities must follow. Both rules aim to protect the privacy and security of individuals' health information.
The document summarizes key implications of the HIPAA Omnibus Rule for organizations that are considered Business Associates. It defines Business Associates and subcontractors as those who create, receive, maintain or transmit protected health information on behalf of covered entities or other business associates. The Omnibus Rule directly regulates business associates and subcontractors under HIPAA, requiring compliance with security and privacy rules. It expands the definition of a breach and penalties for noncompliance, potentially making it more likely organizations will need to notify individuals of breaches. The document provides examples of types of organizations now defined as Business Associates and outlines compliance requirements.
This document discusses new HIPAA regulations and policies to protect patient privacy and secure medical records. It outlines mandatory training for all healthcare employees on HIPAA guidelines and penalties for violations. It also discusses steps to prevent breaches like securing mobile devices and medical equipment. The new 2013 HIPAA policies take effect in March and require full compliance by September, with stricter rules for business associates handling sensitive data and requiring breaches to be reported.
The HIPAA Security Rule - An overview and preview for 2014, from Summit Security Group. Summit Security Group is a business partner to Resource One, managed IT services provider for over 15 years to small and mid-sized businesses in the Portland Metro and Southwest Washington area.
The document provides an overview of the Health Insurance Portability and Accountability Act (HIPAA) basics. HIPAA was enacted in 1996 to protect patients' private health information. It sets guidelines for covered entities like health plans, providers, and clearinghouses to follow regarding use and disclosure of protected health information. HIPAA requires covered entities to provide training to all members on privacy and security of patient data and imposes civil and criminal penalties for improper disclosures without patient consent.
A brief introduction to hipaa compliancePrince George
As you can imagine, complying with federal regulations around privacy and healthcare data is no small task. This presentation is to help you wade through what you need to know about HIPAA compliance as it relates to your application and what steps you’ll need to take to ensure you don’t end up in violation of the law.
There is plenty to research about HIPAA guidelines. This presentation is not meant to be comprehensive, but rather give you a framework and reference to help you understand the major portions of the law.
This document discusses the importance of privacy and confidentiality for patients in healthcare settings. It outlines how laws like HIPAA require extensive training, security measures, and penalties for violations of patient privacy. Ensuring privacy through limited access to patient information, passwords, and locations of medical charts is essential. Regular training of employees helps healthcare organizations maintain focus on upholding patient privacy and confidentiality to prevent breaches.
GDPR is not limited to IT, as it covers any processing of personal data in an organisation. ISO 27001 compliance can be a good starting point, but is not enough for GDPR compliance.
Patient confidentiality and privacy must be maintained to comply with HIPAA regulations. A violation can result in civil penalties up to $25,000 per year or criminal penalties such as fines and imprisonment. All employees should be educated on maintaining confidentiality by protecting passwords, using encryption software, and reporting any breaches to supervisors or an ethics hotline. The document discusses the importance of confidentiality for patients' rights and the legal requirements of HIPAA.
Confidentiality: Effective Training for Healthcare Employeesjacquelinecwinston
This document discusses confidentiality and privacy laws for healthcare organizations, including HIPAA and the HITECH Act. It outlines requirements for notifying individuals and government agencies in the event of a security breach involving protected health information. The document concludes by stating that healthcare employees will be trained on reviewing patient files privately, reporting security breaches appropriately, filing complaints, and full HIPAA compliance.
The document discusses confidentiality and protected health information (PHI) under HIPAA. It provides an overview of HIPAA regulations, what should be covered in training, and consequences for non-compliance. HIPAA provides federal privacy protections for PHI held by covered entities like health care providers and insurance companies. Training should cover security breaches, compliance policies, and procedures for handling breached PHI. PHI includes any past, present, or future health information that can identify a person such as names, addresses, or medical records. Assessments with an 80% passing grade are used to issue completion certificates.
Sensible Care EMS Employee Training on HIPAA requires completion of training for all staff under HIPAA. HIPAA was enacted in 1996 to provide continuous health insurance coverage when changing jobs and reduce costs through standardized electronic transactions. It requires notifying patients of their privacy rights, adopting privacy procedures, training employees, designating a privacy officer, and securing records. Violations can result in civil or criminal penalties. The training program will cover what HIPAA does, who must follow it, protected health information, implementation dates, and why HIPAA is important.
This document provides information on how to implement HIPAA compliance. It begins by explaining what HIPAA is and who it impacts, such as health care providers, health plans, and clearinghouses. It defines protected health information and the obligations of covered entities and business associates. It emphasizes the importance of having business associate agreements, security policies, training programs, and conducting audits. It provides tips for securing data transmission, backups, access controls, and shredding paper records. The document stresses that HIPAA compliance is essential to avoid penalties for violations and data breaches.
Training innovations information governance slideshare 2015Patrick Doyle
What you will learn in this training:
Principles of Information Governance and their application to health and social care organisations
Accessing Information Governance resources including national legislation, guidance and local policies & procedures
Health and social care organisations’ responsibilities
Protection of an individual’s confidentiality and the Caldicott Principles
How to practice and promote a confidential service
Principles of ensuring and maintaining good client records
Recognising / responding to Freedom of Information requests
Keeping Information Secure
Infographic describing the rising number of FINRA and SEC disciplinary actions and fines. It also informs customers about how EAI Information Systems can help companies be compliant and survive audits.
The document discusses the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule and how it protects personal health information. It defines protected health information and outlines requirements for covered entities to implement safeguards, limit disclosures, have contracts with business associates, and provide training to employees on protecting patient privacy and health information. Covered entities must implement administrative, physical and technical safeguards and have procedures in place to limit access to health information.
The document summarizes the key aspects of the HIPAA Privacy Rule. It explains that the rule protects personal health information, gives patients access to their medical records, and protects medical information. Covered entities like healthcare providers and health plans must comply. Protected health information includes information about a patient's health, treatment, and payments. Covered entities must get authorization to disclose certain information like mental health notes or for marketing. Entities must notify patients of their privacy rights and document receipt of the notice. Failure to comply with HIPAA can result in civil penalties up to $25,000 per violation or criminal penalties up to $250,000 for willful offenses.
This document discusses emerging legal trends in cyber insurance. It notes that privacy and data security compliance obligations are increasing in the US, Canada, EU and other countries. Proposed legislation in these regions would strengthen data breach notification laws and privacy regulations. The document also summarizes the types of coverage provided by cyber insurance policies, including third-party liability and first-party coverage. It reviews market trends in cyber insurance premiums and who is buying policies. Tips are provided for selecting a policy, such as ensuring adequate limits and sublimits, and watching for consent and panel requirements that could impact claims handling.
Business associate policy and procedure 10Tara Kresge
This document outlines Ophthalmic Associates of Fort Washington's business associate policy and procedures. It states that the practice will establish business associate agreements with any organization that handles electronic protected health information on its behalf or provides certain services to ensure this information is appropriately safeguarded. The security officer will determine which organizations are considered business associates and require written contracts with them that require reasonable safeguards and security incident notification. Examples of business associates include billing companies, software vendors, transcription services, and medical record storage companies.
The HIPAA Privacy Rule protects individuals' personal health information by setting rules and limits on who can access and receive the information. It provides federal protections for health information held by covered entities and gives patients rights over their data. The HIPAA Security Rule establishes technical and physical safeguards for securing electronic protected health information that covered entities must follow. Both rules aim to protect the privacy and security of individuals' health information.
The document summarizes key implications of the HIPAA Omnibus Rule for organizations that are considered Business Associates. It defines Business Associates and subcontractors as those who create, receive, maintain or transmit protected health information on behalf of covered entities or other business associates. The Omnibus Rule directly regulates business associates and subcontractors under HIPAA, requiring compliance with security and privacy rules. It expands the definition of a breach and penalties for noncompliance, potentially making it more likely organizations will need to notify individuals of breaches. The document provides examples of types of organizations now defined as Business Associates and outlines compliance requirements.
This document discusses new HIPAA regulations and policies to protect patient privacy and secure medical records. It outlines mandatory training for all healthcare employees on HIPAA guidelines and penalties for violations. It also discusses steps to prevent breaches like securing mobile devices and medical equipment. The new 2013 HIPAA policies take effect in March and require full compliance by September, with stricter rules for business associates handling sensitive data and requiring breaches to be reported.
The HIPAA Security Rule - An overview and preview for 2014, from Summit Security Group. Summit Security Group is a business partner to Resource One, managed IT services provider for over 15 years to small and mid-sized businesses in the Portland Metro and Southwest Washington area.
The document provides an overview of the Health Insurance Portability and Accountability Act (HIPAA) basics. HIPAA was enacted in 1996 to protect patients' private health information. It sets guidelines for covered entities like health plans, providers, and clearinghouses to follow regarding use and disclosure of protected health information. HIPAA requires covered entities to provide training to all members on privacy and security of patient data and imposes civil and criminal penalties for improper disclosures without patient consent.
A brief introduction to hipaa compliancePrince George
As you can imagine, complying with federal regulations around privacy and healthcare data is no small task. This presentation is to help you wade through what you need to know about HIPAA compliance as it relates to your application and what steps you’ll need to take to ensure you don’t end up in violation of the law.
There is plenty to research about HIPAA guidelines. This presentation is not meant to be comprehensive, but rather give you a framework and reference to help you understand the major portions of the law.
This document discusses the importance of privacy and confidentiality for patients in healthcare settings. It outlines how laws like HIPAA require extensive training, security measures, and penalties for violations of patient privacy. Ensuring privacy through limited access to patient information, passwords, and locations of medical charts is essential. Regular training of employees helps healthcare organizations maintain focus on upholding patient privacy and confidentiality to prevent breaches.
GDPR is not limited to IT, as it covers any processing of personal data in an organisation. ISO 27001 compliance can be a good starting point, but is not enough for GDPR compliance.
Patient confidentiality and privacy must be maintained to comply with HIPAA regulations. A violation can result in civil penalties up to $25,000 per year or criminal penalties such as fines and imprisonment. All employees should be educated on maintaining confidentiality by protecting passwords, using encryption software, and reporting any breaches to supervisors or an ethics hotline. The document discusses the importance of confidentiality for patients' rights and the legal requirements of HIPAA.
Confidentiality: Effective Training for Healthcare Employeesjacquelinecwinston
This document discusses confidentiality and privacy laws for healthcare organizations, including HIPAA and the HITECH Act. It outlines requirements for notifying individuals and government agencies in the event of a security breach involving protected health information. The document concludes by stating that healthcare employees will be trained on reviewing patient files privately, reporting security breaches appropriately, filing complaints, and full HIPAA compliance.
The document discusses confidentiality and protected health information (PHI) under HIPAA. It provides an overview of HIPAA regulations, what should be covered in training, and consequences for non-compliance. HIPAA provides federal privacy protections for PHI held by covered entities like health care providers and insurance companies. Training should cover security breaches, compliance policies, and procedures for handling breached PHI. PHI includes any past, present, or future health information that can identify a person such as names, addresses, or medical records. Assessments with an 80% passing grade are used to issue completion certificates.
Sensible Care EMS Employee Training on HIPAA requires completion of training for all staff under HIPAA. HIPAA was enacted in 1996 to provide continuous health insurance coverage when changing jobs and reduce costs through standardized electronic transactions. It requires notifying patients of their privacy rights, adopting privacy procedures, training employees, designating a privacy officer, and securing records. Violations can result in civil or criminal penalties. The training program will cover what HIPAA does, who must follow it, protected health information, implementation dates, and why HIPAA is important.
This document provides information on how to implement HIPAA compliance. It begins by explaining what HIPAA is and who it impacts, such as health care providers, health plans, and clearinghouses. It defines protected health information and the obligations of covered entities and business associates. It emphasizes the importance of having business associate agreements, security policies, training programs, and conducting audits. It provides tips for securing data transmission, backups, access controls, and shredding paper records. The document stresses that HIPAA compliance is essential to avoid penalties for violations and data breaches.
The document discusses the HIPAA Omnibus Rule which strengthens privacy and security protection of personal health information and requires compliance by September 2013. It outlines key aspects of the Rule such as its goals to address electronic health records, requirements for covered entities and business associates to protect private health information, and consequences for noncompliance. It also describes how a data loss prevention solution can help organizations meet the new compliance standards by preventing and reporting on improper access to protected health information.
CHAPTER3 Maintaining ComplianceMANY LAWS AND REGULATIONS.docxchristinemaritza
CHAPTER
3 Maintaining Compliance
MANY LAWS AND REGULATIONS ARE IN PLACE regarding the protection of
information technology (IT) systems. Companies have a requirement to comply with the laws that
apply to them. The first step is to understand the laws. You’re not expected to be a lawyer, but you
should understand the basics of relevant laws.
Once you have an idea of which laws and regulations apply, you can then dig in deeper to
ensure your organization is in compliance. The cost of not complying can sometimes be
expensive. Fines can be in the hundreds of thousands of dollars. Some offenses can result in jail
time.
Chapter 3 Topics
This chapter covers the following topics and concepts:
• What U.S. compliance laws exist
• What some relevant regulations related to compliance are
• What organizational policies for compliance should be considered
• What standards and guidelines for compliance exist
Chapter 3 Goals
When you complete this chapter, you will be able to:
• Define compliance
• Describe the purpose of FISMA
• Identify the purpose and scope of HIPAA
• Describe GLBA and SOX, and the impact for IT
• Describe the purpose of FERPA
• Identify the purpose and scope of CIPA
• List some federal entities that control regulations related to IT
• Describe the purpose of PCI DSS
• Describe the contents of SP 800-30
• Describe the purpose of COBIT
• Describe the purpose of ISO and identify some relevant security standards
• Identify the purpose of ITIL
• Identify the purpose of CMMI
U.S. Compliance Laws
Many laws exist in the United States related to information technology (IT). Companies affected
by the laws are expected to comply with the laws. This is commonly referred to as compliance.
Many organizations have internal programs in place to ensure they remain in compliance with
relevant laws and regulations. These programs commonly use internal audits. They can also use
certification and accreditation programs. When compliance is mandated by law, external audits are
often done. These external audits provide third-party verification that the requirements are being
met.
An old legal saying is “ignorance is no excuse.” In other words, you can’t break the law and
then say “I didn’t know.” The same goes for laws that apply to any organization. It’s important for
any organization to know what the relevant laws and regulations are.
You aren’t expected to be an expert on any of these laws. However, as a manager or executive,
you should be aware of them. You can roll any of the relevant laws and regulations into a
compliance program for more detailed checks.
This section covers the following U.S. laws:
• Federal Information Security Management Act (FISMA) 2002
• Health Insurance Portability and Accountability Act (HIPAA) 1996
• Gramm-Leach-Bliley Act (GLBA) 1999
• Sarbanes-Oxley Act (SOX) 2002
• Family Educational Rights and Privacy Act (FERPA) 1974
• Children’s Internet Protection Act (CIPA) 2000
Federal Information ...
The document summarizes a presentation on regulatory compliance with HIPAA and the Omnibus Rule. It discusses key changes introduced by the Omnibus Rule, an overview of HIPAA Privacy and Security requirements, and strategies for achieving compliance. The presentation covers definitions, components of HIPAA, requirements of the Privacy and Security Rules, and safeguards required by the Security Rule.
Presentation designed to explain Business Associates the basics of HIPAA and real-life examples of cases that failed to implement and follow HIPAA requirements on a timely basis.
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) establishes national standards for electronic health care transactions, national identifiers, and security/privacy rules to protect personal health information. HIPAA compliance requirements took effect in 2003, applying to covered entities like health plans, providers, and businesses with access to protected health information. Covered entities must implement policies governing access to and handling of personal health information.
Some of the most significant HiPAA changes will go into effect September 23rd of this year, but impacted businesses will have a full year to implement these new policies
What is HIPAA Compliance?
HIPAA stands for the Healthcare Insurance Portability and Accountability Act of 1996. This specifies laws for the protection and use of Personal (or Protected) Health Information (PHI) - essentially, your medical record. HIPAA sets the standard for protecting sensitive patient data. The Administrative Simplification provisions of the Act (HIPAA, Title II) require the U.S. Department of Health and Human Services (HHS) to adopt certain national standards. These cover electronic health care transactions, and national identifiers for providers, health plans, and employers.
Physical, network, and process security measures are involved. The HIPAA Privacy Rule covers the saving, accessing and sharing of medical and personal information for any individual. The HIPAA Security Rule outlines national security standards to protect health data created, received, maintained or transmitted electronically - also known as electronic protected health information (ePHI).
Meeting these standards? That's compliance.
HIPAA and FDCPA Compliance for Process ServersLawgical
This document provides an overview of the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule and the Fair Debt Collection Practices Act (FDCPA). It summarizes that HIPAA establishes national standards for protecting individuals' personal health information and applies to health plans, providers, and clearinghouses. It also notes that the FDCPA aims to eliminate abusive debt collection practices and applies to debt collectors. Violations of these acts that could affect the reader are discussed.
The document discusses the requirements of HIPAA for protecting patient privacy and securing their health information, including mandates for training and documentation, increased penalties for violations, and rights for patients to access electronic health records; it also outlines the entities covered by HIPAA, defines protected health information, and reviews standards for its use and disclosure for treatment, payment, and healthcare operations.
This white paper discusses how the HIPAA Omnibus Rule expanded regulations for protecting patient health information (PHI) and how businesses can ensure compliance. It explains that the rule now covers business associates that handle PHI for covered entities like healthcare providers. Carbonite's cloud backup solutions are designed to meet HIPAA requirements by encrypting, securing, and allowing emergency access to PHI. The paper outlines Carbonite's administrative, physical, and technical safeguards for complying with HIPAA privacy and security standards.
Does your Mobile App require HIPAA Compliance.pdfShelly Megan
HIPPA or the Health Insurance Portability and Accountability Act is mandatory for healthcare apps handling PHI (Personal Health Information) like identifiable patient information; Covered Entities like healthcare service providers, health plans, and healthcare clearinghouses; and the business associates of covered entities.
The document discusses the Health Insurance Portability and Accountability Act (HIPAA). HIPAA was introduced to protect patient health information and make it easier to keep health insurance between jobs. It sets privacy and security standards for electronic health data. HIPAA compliance is required for covered entities like healthcare providers and plans, and their business associates. It aims to safeguard protected health information while allowing proper healthcare administration.
Chapter 10 Privacy and Security of Health RecordsLearnin.docxcravennichole326
Chapter 10 Privacy and Security of Health Records
Learning Outcomes
After completing this chapter, you should be able to:
♦ List HIPAA transactions and uniform identifiers
♦ Understand HIPAA privacy and security concepts
♦ Apply HIPAA privacy policy in a medical facility
♦ Discuss HIPAA security requirements and safeguards
♦ Follow security policy guidelines in a medical facility
♦ Explain electronic signatures
Understanding HIPAA
In Chapter 11 we will discuss various ways the Internet is being used for healthcare, including various implementations of EHR on the Internet, Internet-based personal health records (PHR), and remote access. In Chapter 12 we will explore the relationship of the EHR data to the determination of codes required for medical billing. Before moving to those topics it is prudent to understand HIPAA. HIPAA is an acronym for the Health Insurance Portability and Accountability Act, passed by Congress in 1996.
The HIPAA law was intended to:
♦ Improve portability and continuity of health insurance coverage.
♦ Combat waste, fraud, and abuse in health insurance and healthcare delivery.
♦ Promote use of medical savings accounts
♦ Improve access to long-term care
♦ Simplify administration of health insurance
HIPAA law regulates many things. However, a portion known as the Administrative Simplification Subsection1 of HIPAA covers entities such as health plans, clearinghouses, and healthcare providers. HIPAA refers to these as covered entities or a covered entity. This means a healthcare facility or health plan and all of its employees. If you work in the healthcare field, these regulations likely govern your job and behavior. Therefore, it is not uncommon for healthcare workers to use the acronym HIPAA when they actually mean only the Administrative Simplification Subsection of HIPAA.
Note Covered Entity
HIPAA documents refer to healthcare providers, plans, and clearing-houses as covered entities. In the context of this chapter, think of a covered entity as a healthcare organization and all of its employees.
As someone who will work with patients’ health records, it is especially important for you to understand the regulations regarding privacy and security. However, let us begin with a quick review of HIPAA, then study the privacy and security portions in more depth.
HIPAA implementation and enforcement is under the jurisdiction of several entities within the U.S. Department of Health and Human Services (HHS). This chapter will make extensive use of documents prepared by HHS.
Administrative Simplification Subsection
The Administrative Simplification Subsection has four distinct components:
1. Transactions and code sets
2. Uniform identifiers
3. Privacy
4. Security
HIPAA Transactions and Code Sets
The first section of the regulations to be implemented governed the electronic transfer of medical information for business purposes such as insurance claims, payme ...
The document provides an overview of various industry regulations discussed in an Information Systems lecture. It summarizes key points about regulations including the Federal Information Security Management Act, Gramm-Leach-Bliley Act, Health Insurance Portability and Accountability Act, Sarbanes-Oxley Act, and California data privacy laws. The lecture emphasizes that major regulations require organizations to implement security controls around authentication, auditing, data protection, and integrity. It also notes an 80/20 rule, where regulations share about 80% of requirements but have 20% industry-specific differences.
The document provides information from a lecture on industry regulations for information systems. It discusses the history of the 3 Musketeers candy bar and various laws and regulations related to information security, including the Federal Information Security Management Act, Gramm-Leach-Bliley Act, Health Insurance Portability and Accountability Act, and their key requirements for protecting sensitive data and systems. It also defines the differences between laws, regulations, and commercial guidance.
Data Privacy Compliance Navigating the Evolving Regulatory Landscape.pdfCIOWomenMagazine
In an increasingly digital world, where personal data has become a valuable commodity, data privacy compliance has emerged as a critical concern for organizations across industries.
Week 1 discussion 2 hipaa and privacy trainingvrgill22
HIPAA was created to establish standards for electronic health information, privacy, and security. It aims to assure health insurance portability, decrease fraud and abuse, and guarantee privacy of patient health information. HIPAA applies to health care providers, health plans, and health care clearinghouses that transmit health information electronically. It protects individually identifiable health information and sets boundaries on its use and disclosure, requiring covered entities to only use and share patient health information as permitted. Covered entities must take steps to remain compliant with HIPAA's privacy and security requirements such as developing policies, training staff, and limiting disclosures to the minimum necessary information.
Similar to HIPAA Omnibus Rule for Business Associates (20)
In today's rapidly advancing technological landscape, the intersection of privacy and innovation has become a paramount concern. One area that has sparked considerable debate and regulatory scrutiny is the use of tracking technologies in the healthcare sector. As healthcare providers strive to improve patient care and streamline operations, they have turned to various tracking technologies to enhance efficiency and data collection. However, the implementation of these technologies raises significant questions about patient privacy and compliance with the Health Insurance Portability and Accountability Act (HIPAA).
HIPAA, enacted in 1996, was designed to safeguard the privacy and security of individuals' medical information. It sets strict guidelines and standards for the handling, storage, and transmission of protected health information (PHI). The law not only applies to healthcare providers but also to their business associates, such as technology vendors and service providers. HIPAA's primary objective is to strike a balance between the need for healthcare organizations to collect and share patient data for treatment and administrative purposes while ensuring the confidentiality and privacy of individuals' sensitive medical information.
Tracking technologies, such as electronic health records (EHRs), wearable devices, and location tracking systems, have shown immense potential in revolutionizing healthcare delivery. EHRs enable healthcare providers to access patient information instantaneously, leading to quicker diagnoses and improved treatment outcomes. Wearable devices, such as fitness trackers and smartwatches, provide real-time health data that can help individuals monitor their well-being and make informed decisions about their lifestyle. Location tracking systems are utilized in hospitals and nursing homes to ensure patient safety and streamline workflows.
While these tracking technologies offer undeniable benefits, they also raise concerns about patient privacy. The vast amount of data generated by these technologies, ranging from personal identifiers to sensitive medical records, demands robust safeguards and strict adherence to HIPAA regulations. Unauthorized access, data breaches, and misuse of patient information can result in severe consequences, including legal repercussions, reputational damage, and loss of patient trust.
In this context, it becomes crucial for healthcare organizations to strike a delicate balance between leveraging tracking technologies to improve patient care and compliance with HIPAA regulations. Robust security measures, such as encryption, access controls, and regular audits, must be implemented to protect patient information from unauthorized access or breaches. Additionally, transparent communication and patient consent are vital to ensure individuals are aware of how their data is being collected, stored, and used.
The current healthcare system in the United States is heavily influenced by HIPAA Security. This translates into a need to understand technology and cybersecurity beyond the use of anti-malware applications. This presentation presents some of the basics Covered Entities and Business Associates must be aware of as it relates to HIPAA Security.
Medicare Access and Chip Reauthorization Act (MACRA) is the law that changes how Providers are to be reimbursed. One of the key characteristics is that it rewards Providers based on value and not volume.
Monthly series covering key subjects regarding healthcare business in the USA. This seminar covers: Affordable Care Act section 1557, HIPAA Security, Medicare Payment models and Chronic conditions.
Brief presentation regarding key topics in the USA healthcare industry. Some of the basic topics include: MACRA, ICD 10, Meaningful Use and a very brief comment about diabetes as a chronic condition.
The document summarizes changes to the 2016 requirements for meaningful use of electronic health records (EHRs). Key changes include replacing core and menu objectives with a single set of objectives and measures for eligible professionals (EPs) and hospitals. EPs have 10 objectives and hospitals have 9 objectives. The objectives focus more on patient outcomes than technology use. Providers will also have more flexibility to customize goals. Audits of EHR meaningful use attestations will continue to ensure compliance. Providers should maintain documentation for at least 6 years to support any audits.
Interesting codes found in ICD-10 and a quick way to code using ICD 9 as a basis. Codes presented are real but presented to simply relax health professionals as they tackle this subject.
Meaningful Use Audits and healthcare compliance course offered to Physicians and healthcare professionals to explain the basics of Meaningful Use and HITECH audits. Course is general in nature as many Physicians and organizations are in different stages of meaningful use.
Taino Consultants, Inc. provides various document management, health records, and security products and services. They offer a document management system, personal health records, remote document safe, electronic medical records, and virtual office solutions. They also assist with business plans, marketing plans, price analyses, IT solutions, website development, training, and compliance. Their clients include healthcare organizations, professionals, government agencies, and start-ups.
Presentations that briefly covers HIPAA and concentrates of the Risk Assessment portion which is a requirement for overall compliance and meaningful use.
Taino Consultants Inc. offers a web-based compliance software to help organizations manage their policies, procedures, forms and documents. The software provides a dashboard interface to access modules for different regulations. It uses security features like encryption and firewalls to protect electronic files stored on the system. The compliance software provides policy updates, reminders, and integrated document management to help users streamline their compliance processes.
Basic explanation of the physician quality reporting system. Some of the due dates and actions that could be taken before Dec 31st to prevent losing money in the future.
Based on misconceptions regarding the exchanges and healthcare reform I created a presentation that covers some of the basic issues and actions to consider.
Review of the health business status in the United States as of July 2013. Brief description of ICD 10 implementation status and potential repercussions and HIPAA Title 2 requirements.
Steps to consider when moving from paper to digital in any business. Solutions presented have been developed by TC Inc. and or Networking team. Steps provided should work on just about any environment and allows for expansion while minimizing growing pains.
Recomendações da OMS sobre cuidados maternos e neonatais para uma experiência pós-natal positiva.
Em consonância com os ODS – Objetivos do Desenvolvimento Sustentável e a Estratégia Global para a Saúde das Mulheres, Crianças e Adolescentes, e aplicando uma abordagem baseada nos direitos humanos, os esforços de cuidados pós-natais devem expandir-se para além da cobertura e da simples sobrevivência, de modo a incluir cuidados de qualidade.
Estas diretrizes visam melhorar a qualidade dos cuidados pós-natais essenciais e de rotina prestados às mulheres e aos recém-nascidos, com o objetivo final de melhorar a saúde e o bem-estar materno e neonatal.
Uma “experiência pós-natal positiva” é um resultado importante para todas as mulheres que dão à luz e para os seus recém-nascidos, estabelecendo as bases para a melhoria da saúde e do bem-estar a curto e longo prazo. Uma experiência pós-natal positiva é definida como aquela em que as mulheres, pessoas que gestam, os recém-nascidos, os casais, os pais, os cuidadores e as famílias recebem informação consistente, garantia e apoio de profissionais de saúde motivados; e onde um sistema de saúde flexível e com recursos reconheça as necessidades das mulheres e dos bebês e respeite o seu contexto cultural.
Estas diretrizes consolidadas apresentam algumas recomendações novas e já bem fundamentadas sobre cuidados pós-natais de rotina para mulheres e neonatos que recebem cuidados no pós-parto em unidades de saúde ou na comunidade, independentemente dos recursos disponíveis.
É fornecido um conjunto abrangente de recomendações para cuidados durante o período puerperal, com ênfase nos cuidados essenciais que todas as mulheres e recém-nascidos devem receber, e com a devida atenção à qualidade dos cuidados; isto é, a entrega e a experiência do cuidado recebido. Estas diretrizes atualizam e ampliam as recomendações da OMS de 2014 sobre cuidados pós-natais da mãe e do recém-nascido e complementam as atuais diretrizes da OMS sobre a gestão de complicações pós-natais.
O estabelecimento da amamentação e o manejo das principais intercorrências é contemplada.
Recomendamos muito.
Vamos discutir essas recomendações no nosso curso de pós-graduação em Aleitamento no Instituto Ciclos.
Esta publicação só está disponível em inglês até o momento.
Prof. Marcus Renato de Carvalho
www.agostodourado.com
Muktapishti is a traditional Ayurvedic preparation made from Shoditha Mukta (Purified Pearl), is believed to help regulate thyroid function and reduce symptoms of hyperthyroidism due to its cooling and balancing properties. Clinical evidence on its efficacy remains limited, necessitating further research to validate its therapeutic benefits.
Basavarajeeyam is a Sreshta Sangraha grantha (Compiled book ), written by Neelkanta kotturu Basavaraja Virachita. It contains 25 Prakaranas, First 24 Chapters related to Rogas& 25th to Rasadravyas.
These lecture slides, by Dr Sidra Arshad, offer a quick overview of the physiological basis of a normal electrocardiogram.
Learning objectives:
1. Define an electrocardiogram (ECG) and electrocardiography
2. Describe how dipoles generated by the heart produce the waveforms of the ECG
3. Describe the components of a normal electrocardiogram of a typical bipolar lead (limb II)
4. Differentiate between intervals and segments
5. Enlist some common indications for obtaining an ECG
6. Describe the flow of current around the heart during the cardiac cycle
7. Discuss the placement and polarity of the leads of electrocardiograph
8. Describe the normal electrocardiograms recorded from the limb leads and explain the physiological basis of the different records that are obtained
9. Define mean electrical vector (axis) of the heart and give the normal range
10. Define the mean QRS vector
11. Describe the axes of leads (hexagonal reference system)
12. Comprehend the vectorial analysis of the normal ECG
13. Determine the mean electrical axis of the ventricular QRS and appreciate the mean axis deviation
14. Explain the concepts of current of injury, J point, and their significance
Study Resources:
1. Chapter 11, Guyton and Hall Textbook of Medical Physiology, 14th edition
2. Chapter 9, Human Physiology - From Cells to Systems, Lauralee Sherwood, 9th edition
3. Chapter 29, Ganong’s Review of Medical Physiology, 26th edition
4. Electrocardiogram, StatPearls - https://www.ncbi.nlm.nih.gov/books/NBK549803/
5. ECG in Medical Practice by ABM Abdullah, 4th edition
6. Chapter 3, Cardiology Explained, https://www.ncbi.nlm.nih.gov/books/NBK2214/
7. ECG Basics, http://www.nataliescasebook.com/tag/e-c-g-basics
Cell Therapy Expansion and Challenges in Autoimmune DiseaseHealth Advances
There is increasing confidence that cell therapies will soon play a role in the treatment of autoimmune disorders, but the extent of this impact remains to be seen. Early readouts on autologous CAR-Ts in lupus are encouraging, but manufacturing and cost limitations are likely to restrict access to highly refractory patients. Allogeneic CAR-Ts have the potential to broaden access to earlier lines of treatment due to their inherent cost benefits, however they will need to demonstrate comparable or improved efficacy to established modalities.
In addition to infrastructure and capacity constraints, CAR-Ts face a very different risk-benefit dynamic in autoimmune compared to oncology, highlighting the need for tolerable therapies with low adverse event risk. CAR-NK and Treg-based therapies are also being developed in certain autoimmune disorders and may demonstrate favorable safety profiles. Several novel non-cell therapies such as bispecific antibodies, nanobodies, and RNAi drugs, may also offer future alternative competitive solutions with variable value propositions.
Widespread adoption of cell therapies will not only require strong efficacy and safety data, but also adapted pricing and access strategies. At oncology-based price points, CAR-Ts are unlikely to achieve broad market access in autoimmune disorders, with eligible patient populations that are potentially orders of magnitude greater than the number of currently addressable cancer patients. Developers have made strides towards reducing cell therapy COGS while improving manufacturing efficiency, but payors will inevitably restrict access until more sustainable pricing is achieved.
Despite these headwinds, industry leaders and investors remain confident that cell therapies are poised to address significant unmet need in patients suffering from autoimmune disorders. However, the extent of this impact on the treatment landscape remains to be seen, as the industry rapidly approaches an inflection point.
Integrating Ayurveda into Parkinson’s Management: A Holistic ApproachAyurveda ForAll
Explore the benefits of combining Ayurveda with conventional Parkinson's treatments. Learn how a holistic approach can manage symptoms, enhance well-being, and balance body energies. Discover the steps to safely integrate Ayurvedic practices into your Parkinson’s care plan, including expert guidance on diet, herbal remedies, and lifestyle modifications.
3. Title I Portability: guarantees health coverage
when employees change jobs
Title II Accountability: Also known as the
Administrative Simplification establishes National
Standards for the protection of health data
◦ Privacy
◦ Security
◦ Enforcement
◦ Electronic Transactions
4. Covered Entity: refers to three specific groups that
normally transmit health information electronically:
◦ health care providers
◦ health plans
◦ health care clearinghouses
Business Associate: Person/agency who performs
a function or activity for or on behalf of a covered
entity that involves the use of patient information
5. Addresses a number of rules and incorporates them into
itself as the definitive requirements for compliance.
1. Implemented changes to HIPAA that were mandated by the
2009 Health Information Technology for Economic and
Clinical Health Act (HITECH);
2. Finalized the 2009 Enforcement and Breach Notification
Interim Final Rules; and
3. Modified HIPAA's Privacy Rule to strengthen the
protections for genetic information required under the
Genetic Information Nondiscrimination Act of 2008
(GINA).
6. Business Associate definition expanded to include
any entity that creates, receives, maintains or
transmits PHI on behalf of a Covered Entity or an
organized health care arrangement.
Broadened the definition of Business Associate to
include any downstream subcontractors of
Business Associates
Liability and compliance rules expanded to include
BA and its subcontractors
7. “All those entities that create, receive, maintain, or
transmit PHI on behalf of a covered entity.”
◦ Data storage company that stores physical or electronic
data;
◦ Software vendors
◦ Insurance sales agents and vendors
◦ Professionals (lawyers, consultants, lawyers)
“It is what you do, not what you call yourself, that
determines whether you are a Business Associate”
9. Analyze whether you are now considered
Business Associates;
Assess whether your subcontractors/vendors are
considered Business Associates;
Conduct audits and gap analysis;
Revise/Implement Policies and Procedures;
Revise/Implement Agreements;
Train employees.
10. Posted in Federal Register: Jan 25, 2013
Effective date: March 26,2013
Compliance date: September 23, 2013
11. Do not delay actions
Enforcement date is Sep 2013
◦ Compliance steps may take over 6 months
If in doubt consult an expert
Dr. Jose I. Delgado is the President and CEO of Taino Consultants Inc.,
consulting firm that focuses on healthcare business start-ups, compliance and
operations. Dr. Delgado can be contacted at
DrDelgado@TainoConsultants.com.
Editor's Notes
The Health Insurance Portability and Accountability Act of 1996 ( HIPAA ; Pub.L. 104-191 , 110 Stat. 1936, enacted August 21, 1996) was enacted by the United States Congress and signed by President Bill Clinton in 1996. It was sponsored by Sen. Nancy Kassebaum (R-Kan.). Title I of HIPAA protects health insurance coverage for workers and their families when they change or lose their jobs. Title II of HIPAA, known as the Administrative Simplification (AS) provisions, requires the establishment of national standards for electronic health care transactions and national identifiers for providers, health insurance plans, and employers
The Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-191, included Administrative Simplification (AS) provisions (Title II) that required national standards for electronic health care transactions and code sets, unique health identifiers, and security. AS also covered the areas of Privacy, Security, Enforcement and Electronic Transactions. The Privacy Rule set national standards for the protection of individually identifiable health information while the security rule emphasized the protections of information in electronic format. The enforcement rule established the procedures and penalties in case of unauthorized releases.
The term "covered entity" under the HIPAA Privacy Rule refers to three specific groups, including health plans, health care clearinghouses, and health care providers that transmit health information electronically. Covered entities under the HIPAA Privacy Rule must comply with the Rule's requirements for safeguarding the privacy of protected health information. Below is a more detailed list of those who fall under the covered entity category under HIPAA. Health Care Providers This includes all health care providers, regardless of practice size, provided that they transmit health information electronically. The specific electronic transactions subject to this rule are those that are covered under the HIPAA Transactions Rule. Providers subject to the Privacy rule include: o Doctors, o Clinics, o Psychologists, o Dentists, o Chiropractors, o Nursing Homes, and, o Pharmacies. Health Plans Medical, Dental, and Vision Plans HMOs Medicare and Medicaid Medicare+Choice and Medicare Supplement Insurers Long-Term Care Insurers (excluding nursing home fixed-indemnity policies) Veterans Health Plans Company Health Plans Exceptions include: o A group health plan with less than 50 participants that is administered solely by the employer that established and maintains the plan is not a covered entity; o Government-funded programs whose principal purpose is not providing or paying the cost of health care; o Government-funded programs whose principal activity is directly providing health care or the making of grants to fund the direct provision of health care; and, o Certain types of insurance entities such as those providing only workers' compensation, automobile insurance, and property and casualty insurance. Health Care Clearinghouses Entities that process nonstandard health information they receive from another entity into a standard (i.e., standard electronic format or data content), or vice versa. This includes: o Billing Services, o Repricing Companies, o Community Health Management Information Systems, and, o Value-added networks and switches if these entities perform clearinghouse functions.
Amendments to the Enforcement Rule: Increased Penalties and Fewer Defenses Even for covered entities that have long been subject directly to HIPAA regulations, the stakes will now be higher. The HITECH Act raised the maximum penalty for HIPAA violations to $50,000 per violation and $1.5 million for a group of identical violations. 31 These increased penalties will now apply to violations by covered entities and business associates alike. The revised Enforcement Rule limits the affirmative defenses available to an entity that violates HIPAA. A complete defense is available only if the violation was not due to willful neglect and was corrected within thirty days of when the entity knew, or by exercising “reasonable diligence” would have known, of the violation. This means that an entity’s reasonable lack of knowledge of a violation, alone, will no longer constitute a complete defense, which it had in the past. Moreover, an employee or business associate’s knowledge of a violation may be imputed to a covered entity. In addition, business associates will become directly liable for their breaches. HIPAA requires BAAs to provide that business associates must notify the covered entity upon discovery of any violation. The new rules also make business associates directly liable for the failure to provide such notice. A covered entity or business associate is non-compliant if it knows “of a pattern of activity or practice of [its business associate or subcontractor] that constituted a material breach or violation of the [BAA],” unless the superior either took “reasonable steps” to cure the breach or end the arrangement. 8 Even when a subordinate’s potentially violative activity is not known, the supervising authority may be liable for the violation if the subordinate was acting as the “agent” of the covered entity or business associate. 39