Minimum Content of Policies and Procedures. At a minimum, the Policies and Procedures shall be reviewed and updated, as necessary, to address the following Privacy Rule provisions:
1. Right of Access (45 C.F.R. § 164.524), including procedures to ensure comprehensive and timely responses to access requests to PHI.
2. Training (45 C.F.R. § 164.530(b)(1)), including protocols for training all Renown workforce members that are involved in receiving or fulfilling access requests as necessary and appropriate to ensure compliance with the policies and procedures provided for in Section V.A. above.
3. Sanctions (45 C.F.R. § 164.530(e))
Minimum Content of Policies and Procedures. The Policies and Procedures shall include, but not be limited to:
1. Review and update as necessary RPMG’s policy regarding Right of Access to PHI to ensure timely and appropriate response to requests for records and a denial process consistent with the Privacy Rule.
2. Protocols for training all RPMG’s workforce members or business associates that are involved in receiving or fulfilling access requests as necessary and appropriate to ensure compliance with the policies and procedures provided for in section V.A above.
3. Application of appropriate sanctions against RPMG workforce members who fail to comply with policies and procedures provided for in subparagraph (1) above.
Minimum Content of Policies and Procedures. The Policies and Procedures shall include, but not be limited to:
1. Review and update as necessary NYSM’s Right of Access to PHI policy to ensure comprehensive responses to requests for records.
2. Protocols for training all NYSM’s workforce members that are involved in receiving or fulfilling access requests as necessary and appropriate to ensure compliance with the policies and procedures provided for in section V(A) above.
3. Application of appropriate sanctions against NYSM workforce members who fail to comply with policies and procedures provided for in subparagraph (1) above.
4. Review and update as necessary NYSM’s policy for cooperation with investigations and compliance reviews conducted by the Secretary to ensure comprehensive responses to compliance investigations and reviews.
5. Protocols for training all NYSM’s workforce members that are involved with cooperating with investigations and compliance reviews conducted by the Secretary to ensure compliance with the policies and procedures provided for in section V(A) above.
6. Application of appropriate sanctions against NYSM workforce members who fail to comply with policies and procedures provided for in subparagraph (1) above.
Minimum Content of Policies and Procedures. The Policies and Procedures referred to in Section V.A.1 shall include, but not be limited to:
1. Review and update as necessary Banner Health’s “Patient Request for Records” policy to ensure comprehensive and accurate responses to requests for records.
2. Protocols for training all Banner Health’s workforce members that are involved in receiving or fulfilling access requests as necessary and appropriate to ensure compliance with the policies and procedures provided for in Section V.A.1 above.
3. Application of appropriate sanctions against Banner Health workforce members who fail to comply with policies and procedures provided for in Section V.A.1 above.
Minimum Content of Policies and Procedures. The Policies and Procedures shall include, but not be limited to:
1. Review and update as necessary Xxxxxx’x Right of Access to PHI policy to ensure comprehensive and timely responses to requests for records. 45 C.F.R. §164.524
2. Protocols for training all Xxxxxx ’s workforce members and business associates that are involved in receiving or fulfilling access requests as necessary and appropriate to ensure compliance with the policies and procedures provided for in section V.A. above.
3. Application of appropriate sanctions against Xxxxxx workforce members who fail to comply with policies and procedures provided for in subparagraph (1) above.
4. A process for reviewing business associate performance with regard to access requests and responses and terminating relationships with business associates who fail to permit Xxxxxx to comply with policies and procedures provided for in subparagraph
(1) above.
5. Designation of one or more individuals who are responsible for ensuring that Xxxxxx’x business associate agreement with any business associates involved in Xxxxxx’x access responsibilities under the Privacy Rule are properly executed.
Minimum Content of Policies and Procedures. The Policies and Procedures required by Paragraph V.A above shall include, but not be limited to, the following provisions, standards, implementation specifications and obligations:
1. Uses and Disclosures of PHI - 45 C.F.R. § 164.502(a) 2. Minimum Necessary - 45 C.F.R. § 164.502(b)
3. Disclosures to Business Associates- 45 C.F.R. § 164.502(e)(1) 4. Training – 45 C.F.R. § 164.530(b)(1) 5. Safeguards - 45 C.F.R. § 164.530(c)(1) 6. Changes to Policies and Procedures - 45 C.F.R. § 164.530(i)(2)
7. Administrative Safeguards, including all required and addressable implementation specifications – 45 C.F.R. § 164.308(a) and (b). 8. Physical Safeguards, including all required and addressable implementation specifications – 45 C.F.R. § 164.310.
Minimum Content of Policies and Procedures. The Policies and Procedures required under Section V.A. shall include, but not be limited to:
1. All obligations required under 45 C.F.R. §164.524 and all its subparts;
2. Accurate definition of a “Designated Record Set” as defined in the Privacy Rule; and
3. Protocols for training all SRMC’s workforce members that are involved in receiving or fulfilling access requests as necessary and appropriate to ensure compliance with the policies and procedures provided for in Section V.A above.
Minimum Content of Policies and Procedures. The Policies and Procedures shall include, but not be limited to:
1. All obligations required under 45 C.F.R. §164.524 and all its subparts;
2. An accurate definition of a “Designated Record Set” as defined in the Privacy Rule;
3. Standardized procedures for responding to requests for access pursuant to 45 C.F.R. §164.524;
4. Protocols for training all UCMC’s workforce members and business associates that are involved in receiving or fulfilling access requests as necessary and appropriate to ensure compliance with the policies and procedures provided for in section V.A. above;
5. Protocols for training UCMC’s workforce members that are involved in the maintaining of designated record sets and other protected health information as necessary and appropriate to ensure compliance with the policies and procedures provided for in section V.A. above.
6. Application of appropriate sanctions against UCMC workforce members who fail to comply with policies and procedures; and
7. A process for reviewing business associate performance with regard to access requests and responses and sanctioning business associates who fail to permit UCMC to comply with its HIPAA policies and procedures;
Minimum Content of Policies and Procedures. The Policies and Procedures shall include, but not be limited to:
1. Review and update as necessary the Covered Entity’s Designated Record Set Policy contained within its Right of Access to PHI policy to ensure comprehensive responses to requests for records.
2. Protocols for training all the Covered Entity’s workforce members that are involved in receiving or fulfilling access requests as necessary and appropriate to ensure compliance with the policies and procedures provided for in section V.A. above.
3. Application of appropriate sanctions against the Covered Entity workforce members who fail to comply with policies and procedures provided for in subparagraph (1) above.
4. Review and update as necessary the Covered Entity’s Designated Record Set Policy contained within its Right of Access to PHI policy to ensure the provision of a standard method for requesting access for personal representatives versus individuals with whom the Covered Entity is authorized to share PHI.
Minimum Content of Policies and Procedures. The Policies and Procedures shall include, but not be limited to:
1. Review and update as necessary SJHMC’s Designated Record Set Policy contained within its Right of Access to PHI policy to ensure comprehensive responses to requests for records.
2. Protocols for training all SJHMC ’s workforce members and business associates that are involved in receiving or fulfilling access requests as necessary and appropriate to ensure compliance with the policies and procedures provided for in section V.A. above.
3. Application of appropriate sanctions against SJHMC workforce members who fail to comply with policies and procedures provided for in subparagraph (1) above.
4. A process for reviewing business associate performance with regard to access requests and responses and terminating relationships with business associates who fail to permit SJHMC to comply with policies and procedures provided for in subparagraph
(1) above.
5. Designation of one or more individuals who are responsible for ensuring that SJHMC’s business associate agreement with any business associates involved in SJHMC’s access responsibilities under the Privacy Rule are properly executed.
