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Resource Overview

Conducting an SRA in accordance with HIPAA policy is a complex task, especially for small to medium providers such as community health centers. The HIPAA Security Rule mandates security standards to safeguard electronic Protected Health Information (ePHI) maintained by electronic health record (EHR) technology, with detailed attention to how ePHI is stored, accessed, transmitted, and audited. This rule is different from the HIPAA Privacy Rule, which requires safeguards to protect the privacy of PHI and sets limits and conditions on it use and disclosure. Meaningful Use supports the HIPAA Security Rule. In order to successfully attest to Meaningful Use, providers must conduct a security risk assessment (SRA), implement updates as needed, and correctly identify security deficiencies. By conducting an SRA regularly, providers can identify and document potential threats and vulnerabilities related to data security, and develop a plan of action to mitigate them.

Security vulnerabilities must be addressed before the SRA can be considered complete. Providers must document the process and steps taken to mitigate risks in three main areas: administration, physical environment, and technical hardware and software. The following set of resources provide education, strategies and tools for conducting SRA.

Security Risk Analysis Resources
Compliance with 42 CFR Part 2: A Case Study with Community Medical Centers, Inc.
HITEQ Center

Compliance with 42 CFR Part 2: A Case Study with Community Medical Centers, Inc.

Developed by HITEQ with Adapt Health Information Technology and Chiron Strategy Group

Health centers are actively expanding the substance use treatment services they offer in the community to address access to care for opioid use disorders, and more broadly to address better screening, referral and timely access to all substance use disorder (SUD) treatment. The downloadable case study below is an example of how a health center is assessing operations to comply with 42 CFR Part 2, with a particular focus on changes to their health information technology (IT) systems.

What is 42 CFR Part 2 and when does it apply for health centers? 

The purpose of Title 42 of the Code of Federal Regulations (CFR) Part 2: Confidentiality of Substance Use Disorder Patient Records (Part 2)  is to address concerns about the use of substance use disorder (SUD) information in non-treatment based settings. Part 2 is intended to ensure that a patient receiving treatment for a SUD in a Part 2 Program does not face adverse consequences in criminal or domestic proceedings such as those related to child custody, divorce or employment. Part 2 protects the confidentiality of SUD patient records by restricting the circumstances under which Part 2 Programs can disclose information. Part 2 is applicable to federally assisted programs who provide and hold themselves out as providing SUD services including diagnosis, treatment, or referral for treatment.  Providers in general facilities whose primary function is to provide diagnosis, treatment, or referral for treatment for a SUD are also considered “programs”. 

Compliance with Part 2 will likely involve a number of changes for health centers including changes to clinical documentation and data segregation in the EHR, suppression of data sharing across HIE’s and other networks, changes to workflows, and changes to patient intake and patient-facing forms. For health centers that have emphasized and pursued data sharing and exchange, putting these protections in place may feel like working backwards in systems that are designed for automated sharing. 

For more information, please see 42 CFR Part 2 Final Rule and Health Center Compliance in the HITEQ webinar archives.

The case study, available for download below, includes a 42 CFR Part 2 Regulatory Checklist that health centers may find particularly helpful to review.

Download the full case study below.

 

Documents to download

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Intended AudienceHealth Center Leadership, Behavioral Health Teams and Providers, Health IT Staff, Care Team Leaders

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Acknowledgements

This resource collection was cultivated and developed by the HITEQ team with valuable suggestions and contributions from HITEQ Project collaborators.

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