The Omnibus Rule compliance date is September 23, 2013. You may be feeling overwhelmed and thinking that you cannot possibly get your organization completely HIPAA compliant in just 10 days. Maybe not, but you can still set in motion some things that may help keep you out of hot water—or at least not such deep hot water—in case that the feds come calling. For example, you could immediately update your risk analysis (or complete your initial risk analysis), document it in writing, and put a written plan in place to implement any necessary security and privacy measures that you may need with anticipated dates. This step could help you avoid any allegations of willful neglect if you experience a breach, for example.
In case you want a quick reminder of changes that the Omnibus Rule will cause, you could use one (or all) of the four supplements that I have written and have had posted on the Premium Member section of the Veterans Press website, one supplement for each of these books: The Compliance Guide to HIPAA and the DHHS Regulations, 5th ed.; How to Handle HIPAA and HITECH Act Breaches, Complaints, and Investigations: Everything You Need to Know; Mental and Behavioral Health and HIPAA: An Uneasy Alliance; and Have You Heard about HIPAA? A Practical HIPAA Compliance Guide for Audiologists and Speech Pathologists.
Also, if you are still having trouble justifying to the powers that be why they need to spend money to achieve HIPAA compliance, you may want to show them my latest article published in the Summer 2013 issue of the Journal of Health Care Finance, “The Law of Unintended (Financial) Consequences: The Expansion of HIPAA Business Associate Liability,” also now posted for you on our Premium Member section of the Veterans Press website.
Again, as a reminder, if you bought the HIPAA Compliance Library that includes my 5th edition of the Compliance Guide to HIPAA and the DHHS Regulations, you received with it a one-year free subscription to the Premium Member section. If you need help setting up your account to access the Premium Member section, please call our marketing director, Patrick R. Head II, toll-free at 855-341-8783 or email him at patrick@veteranspress.com.
Also, if you are really desperate, contact Patrick to set up a HIPAA consult with us through EMR Legal, Inc., a subsidiary of Veterans Press.
