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The Coalfire Blog

All Aboard the HIPAA Omnibus - but is the ‘bus’ missing anything?

February 06, 2013, Andrew Hicks, Managing Principal, Coalfire

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Andrew Hicks

In the wake of the recently-released HIPAA Omnibus Rule with its upcoming deadline, healthcare organizations are trying to figure out how they’re going to achieve compliance. We’ve been busy trying to get through the 563-page rule and determine what it means to our clients.

We spoke with this week about fielding calls from our healthcare customers who are asking how they should proceed with the security and privacy changes that will now go into effect. After going through the entire Omnibus Rule, we can say with complete confidence that we’re prepared to help them meet the new requirements.

The most interesting thing that we’ve found is not what IS included in the final rule, but what’s NOT included.  One thing that’s missing is a call for more rigorous testing and audit program guidelines that would minimize the subjectivity and vagueness associated with the existing requirements. Perhaps it’s too early to have incorporated the final results from the pilot OCR audits in 2012, but those results will yield valuable information, no doubt.  We also think that the industry needs to either adopt a security framework, similar to the HITRUST Common Security Framework (CSF), or publish more comprehensive assessment criteria.

The adoption (or even a mention) of new medical technologies such as cloud computing environments, ePHI on mobile devices, and the need for internal/external vulnerability scans and penetration testing are glaring omissions from the final rule.  We are speaking on this topic of ‘what’s missing’ at the 21st National HIPAA Summit conference later this month in Washington, D.C., so we hope to see you there!

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