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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

Telehealth Policy during Coronavirus/ COVID-19 Pandemic

Updated regularly in March and April 2020

We are adding additional telehealth information, including policy and regulatory developments, relevant to coronavirus/ COVID-19 pandemic as it impacts health centers as it becomes available. Please see the resource links below.

 

  • CMS Loosens Restrictions on RHC and FQHC Telemedicine Services – COVID-19 Updates

    • Published by BKD on April 10, 2020.
    • Key Information: Coding and regulatory requirements for implementing telehealth in accordance with CMS's loosened restrictions. Effective March 27, 2020, the CARES Act removed restrictions in place prior to the COVID-19 emergency, and now allows FQHCs to serve as distant site providers for telehealth audiovisual (but not audio-only or telephone) visits, and these can be rendered to new or established patients. CMS also added 80 codes to the existing list of eligible telehealth (audiovisual) services.

 

  • Telehealth Coverage Policies In The Time Of COVID-19 to Date

    • Published by the Center for Connected Health Policy, updated regularly in March and April 2020.
    • Key Information: Telehealth waivers under Medicare and Medicaid are in place, as well as DEA actions permitting prescriptions for controlled substances via telemedicine. Scroll to the bottom of the page for FQHC specific information.

 

 

 

 

  • Telehealth and Telephone Visits in the Time of COVID-19: Sample FQHC Workflows

    • Published by the Center for Care Innovations, March 24, 2020.
    • Key Information: Many health centers and safety net clinics are switching their scheduled in-person visits to telephone or video visits, this resource provides some sample workflows and guidance for how clinics are making this transition, including examples from eClinicalWorks, NextGen, and OCHIN Epic. 
    • An appointment rescheduling flowsheet from a health clinic is available from NEMJ.

 

  • COVID-19 Public Health Emergency Response and 42 CFR Part 2 Guidance

    • Published by the Substance Abuse and Mental Health Services Administration (SAMHSA) on March 19, 2020.
    • Key Information: There has been an increased need for telehealth services, and in some areas without adequate telehealth technology, providers are offering telephonic consultations to patients. In such instances, providers may not be able to obtain written patient consent for disclosure of substance use disorder records. The prohibitions on use and disclosure of patient identifying information under 42 C.F.R. Part 2 would not apply in these situations to the extent that, as determined by the provider(s), a medical emergency exists.

 

  • State Data and Policy Actions to Address Coronavirus

    • Published and updated March and April 2020 by Kaiser Family Foundation.
    • Key information: This site is tracking state-by-state policy actions such as state waivers of cost sharing for COVID-19 testing, state waivers of prior authorization requirements, early perscription refills, and expanded marketplace insurance enrollment.
    • Other important sources of state information are Medicaid Federal Disaster Resources which includes details on each state’s 1135 Waiver as approved by CMS and the Center for Connected Health Policy's tracking of COVID-19 related state actions.

 

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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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