This template goes through common steps for HIPAA compliance. Things such as establishing the necessary security roles in your organization as well as assessments and training.
This diagram was created on Feb 19, 2021 8:33 PM and was last updated Mar 8, 2021 9:36 AM.
Designate a Compliance, Security & Privacy Officer
You must first designate a Compliance, Security & Privacy Officer for your organization. - Compliance Officer: is responsible for developing compliance & training programs as well as managing business associate agreements. - Security Officer: is responsible for compliance with the Administrative, Physical and Technical Safeguards of the Security Policies. - Privacy Officer: is responsible for developing a HIPAA-compliant privacy program, oversee ongoing employee privacy training, conduct risk assessments and develop HIPAA-compliant procedures where necessary.
Conduct Security Risk Assessment
Following the NIST Guidelines, conduct a Security Risk Assessment on your organization. A risk assessment helps reveal areas where your organization’s protected health information (PHI) could be at risk.
Conduct Privacy Assessment
Conduct a Privacy Assessment on your organization. Identify and mitigate risks, including risks to confidentiality, at every stage of the system life cycle.
Conduct Administrative Assessment
Conduct an Administrative Assessment and evaluate what policies does your organization currently have in place to ensure the security of PHI.
Document all deficiencies from assessments
Create a document that itemizes all of the deficiencies from the following: - Security Risk Assessment - Privacy Assessment - Administrative Assessment
List of Deficiencies
This is a document of all the deficiencies from the following: - Security Risk Assessment - Privacy Assessment - Administrative Assessment
Have all deficiencies been identified and documented?
Have you identified all deficiencies discovered during the audits? Have you documented all deficiencies?
Create remediation plans to address deficiencies
Using the deficiencies from the audits, create remediation plans to address the deficiencies for the following: - Security Risk Assessment - Privacy Assessment - Administrative Assessment
Remediation Plan
Remediation Plan that addresses the deficiencies in the following audits: - Security Risk Assessment - Privacy Assessment - Administrative Assessment
Develop Policies & Procedures for Privacy, Security & Breaches
Create Policies and Procedures relevant to the HIPAA Privacy, Security, and Breach Notification Rules.
Policies & Procedures
Document the Policies & Procedures for HIPAA Privacy, Security and Breach Notification Rules.
Communicate the Policies & Procedures
Make your Policies & Procedures clearly available to everyone in your organization. Take time to review the Policies & Procedures with your staff.
Attestation to Policies & Procedures?
Have all staff members read and attested to the Policies and Procedures?
Document Attestation
Document the Attestation to Policies & Procedures from all staff members.
Attestation to Policies & Procedures
This is the document of everyone staff member's Attestation to the Policies & Procedures.
Develop a Compliance & Training Program
Develop a Compliance & Training program that makes it clear for everyone in your organization what your policies are and how to remain compliant. Training materials should also provide a more comprehensive overview of HIPAA compliance.
Compliance & Training Program
This is the document for your organization's Compliance & Training Program.
Perform Annual HIPAA Training
Require all staff members perform an Annual HIPAA Training based on your Compliance & Training program.
Training Certificate
Require certificates for completion of your organization's HIPAA Training.
Establish Business Associate Agreements
The HIPAA Privacy Rule requires all Covered Entities to have a signed Business Associate Agreement (BAA) with any Business Associate (BA) they hire that may come in contact with PHI. Establish any entity in which you have a business association and require a signed BAA.
Audit Business Associates and ensure they are HIPAA compliant
Perform an audit on all of your BAs to ensure that they are HIPAA compliant.
Business Associate Agreements
This is the document for all signed BAAs.
Develop a process for incidents or breaches
Develop a process for investigating minor or meaningful incidents or breaches. This should include the necessary steps for performing an investigation and how to document and report the incident or breach.
Do you have a process in the event of incidents or breaches?
Do you have the ability to track and manage the investigations of all incidents? Are you able to demonstrate that you have investigated each incident? Are you able to provide reporting of minor or meaningful breaches or incidents? Do your staff members have the ability to anonymously report an incident?
Process Documentation for Incidents or Breaches
This is the documentation of the process for an incident or breach. This document should describe the necessary steps to perform an investigation and how to document the report.
Anonymously report incident
Do your staff members have the ability to anonymously report an incident? This is an example of a staff member anonymously reporting an incident.
Anonymous Incident Report
This is the document that represents an anonymous incident report of a minor or meaningful breach or incident.
Investigate the Incident
Track and manage the investigation of the incident and document the steps you have taken for the investigation.
Investigation Report of minor or meaningful breach or incident
This is the document of your Investigation Report of the breach or incident.