HIPAA policy management is the practice of developing, reviewing, and updating HIPAA policies, and ensuring that current versions of each policy are accessible to all members of the workforce on demand. When done effectively, good HIPAA policy management is a vital tool for supporting HIPAA compliance across the organization.
Organizations that qualify as HIPAA covered entities or business associates are required to develop and implement policies designed to comply with all applicable standards of the HIPAA Administrative Simplification Regulations. In many cases, this may mean an organization has to develop and implement hundreds of HIPAA policies – and ensure compliance with them all.
To support compliance, workforce members must be trained on HIPAA privacy policies with respect to Protected Health Information (PHI) that are relevant to their roles. They must also receive training on security policies developed to support HIPAA compliance as part of an ongoing security awareness program developed in accordance with the General Requirements of the HIPAA Security Rule.
Many organizations that qualify as HIPAA covered entities or business associates may find HIPAA policy management complex. This is because policies may have to be reviewed and updated whenever there is an operational, technical, or regulatory change to activities. If a change is material to a workforce member’s role, the workforce member must also be provided with additional HIPAA training.
What HIPAA Policy Management Consists Of
HIPAA policy management consists of documenting, versioning, and scheduling reviews of HIPAA policies to ensure they are always current. To manage HIPAA policies effectively, an organization should designate a cross-functional team with the responsibility for HIPAA policy management to ensure policies reflect operational realities and are robust enough to address technical or regulatory changes.
While each team member may be assigned responsibility for managing HIPAA policies for the areas of HIPAA compliance they are responsible for (patient privacy, data security, business associate relations, etc.), HIPAA policies and other connected workplace policies should be maintained in the same repository to support cross-referencing when a change to one HIPAA policy affects compliance with other HIPAA policies.
A HIPAA policy review cycle should also be established to comply with the requirement to conduct periodic non-technical evaluations (§164.308(a)(8)), and ensure that any subtle shifts in operational activities, technology configurations, or regulatory guidance are not overlooked. Changes to HIPAA policies – and the rationale behind them – should be documented, revised documents must be version controlled, and replaced documents archived securely.
The Benefits of Policy Automation Software
The potential volume of reviews, changes, and documentation requirements makes it very difficult for an organization to manage HIPAA policies manually. For this reason, many organizations take advantage of automated HIPAA policy management – a feature of HIPAA compliance software that often includes real-time regulatory monitoring, integrated risk assessments, and policy change audit capabilities.
In most cases, the automation platform includes a centralized digital repository for HIPAA polies that enables organizations to assign different access controls so that those with the authority to change HIPAA polices have “write” permissions, while other members of the workforce who may need to access HIPAA policies, training content, or other documentation (i.e., HIPAA authorization forms) only have “read” permissions.
An automated and searchable policy portal ensures that all members of the workforce have access to the most recent HIPAA policies with the click of a mouse and remotely. This can help support HIPAA compliance across the organization if doubts exists about what policy applies in specific circumstances or if a workforce member needs to better understand the rationale about why a HIPAA policy applies.
As the benefits of automated HIPAA policy management can also save HIPAA covered entities and business associates time and money managing HIPAA policies manually, organizations that have not yet evaluated automated HIPAA policy management are advised to review their existing HIPAA policy management practices and determine whether their organization could benefit from HIPAA compliance software with policy automation capabilities.