|
Scheduled
Completion Date |
Responsible Party |
Document Index # |
Comments |
Transactions |
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|
|
|
| Claims
I 837 |
|
|
|
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| Claims
P 837 |
|
|
|
|
| Claims
D 837 |
|
|
|
|
| Remittance
835 |
|
|
|
|
| Eligibility
Inquiry |
|
|
|
|
| Eligibility
Response |
|
|
|
|
| Claims
Status Inquiry |
|
|
|
|
| Claims
Status Response |
|
|
|
|
| Referrals
278 |
|
|
|
|
| Claims
I 837 System data |
|
|
|
|
| Claims
P 837 System data |
|
|
|
|
| Claims
D 837 System data |
|
|
|
|
| Remittance
835 System data |
|
|
|
|
| Eligibility
Inquiry System data |
|
|
|
|
| Eligibility
Response System data |
|
|
|
|
| Claims
Status Inquiry System data |
|
|
|
|
| Claims
Status Response System data |
|
|
|
|
| Referrals
278 System data |
|
|
|
|
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|
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|
Security |
|
|
|
|
Administrative Procedures |
|
|
|
|
| Certification |
|
|
|
|
| Chain
of Trust Partner Agreement |
|
|
|
|
| Contingency
plan |
|
|
|
|
| Applications
and data criticality analysis |
|
|
|
|
| Data
backup plan |
|
|
|
|
| Disaster
recovery plan |
|
|
|
|
| Emergency
mode operation plan |
|
|
|
|
| Testing
and revision |
|
|
|
|
| Formal
mechanism for processing records |
|
|
|
|
| Information
access control |
|
|
|
|
| Access
authorization |
|
|
|
|
| Access
establishment |
|
|
|
|
| Access
modification |
|
|
|
|
| Internal
Audit |
|
|
|
|
| Personnel
security |
|
|
|
|
| Maintenance
of record of access authorizations |
|
|
|
|
| Personnel
clearance procedure |
|
|
|
|
| Personnel
security policy/procedure |
|
|
|
|
| Comprehensive
written personnel security policy |
|
|
|
|
| Written
notice to all new temporary personnel |
|
|
|
|
| Written
notice to all medical and nursing staff |
|
|
|
|
| Annual
review of the Security Policy-required by everyone |
|
|
|
|
| Written
acknowledgement (signature) by everyone |
|
|
|
|
| Procedures
in place to enforce and monitor the Security Policy |
|
|
|
|
| Tracking
system operational to track and report Security notice deficiencies |
|
|
|
|
| System
users, including maintenance personnel, trained in security |
|
|
|
|
| Security
configuration management |
|
|
|
|
| Documentation |
|
|
|
|
| Hardware
and software installation and maintenance review and testing for
security features |
|
|
|
|
| Inventory |
|
|
|
|
| Security
testing |
|
|
|
|
| Virus
testing |
|
|
|
|
| Security
incident procedures |
|
|
|
|
| Report
procedures |
|
|
|
|
| Response
procedures |
|
|
|
|
| Security
management process |
|
|
|
|
| Risk
analysis |
|
|
|
|
| Risk
management |
|
|
|
|
| Sanction
policy |
|
|
|
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| Security
policy |
|
|
|
|
| Termination
procedures |
|
|
|
|
| Combination
locks changed |
|
|
|
|
| Removal
from access lists |
|
|
|
|
| Removal
of user account(s) |
|
|
|
|
| Turn
in keys, token or cards that allow access |
|
|
|
|
| Training |
|
|
|
|
| Awareness
training for all personnel |
|
|
|
|
| Periodic
security reminders |
|
|
|
|
| User
education concerning virus protection |
|
|
|
|
| User
education in monitoring log in success/failure, and how to report
discrepancies |
|
|
|
|
| User
education in password management |
|
|
|
|
| Other
Administrative Procedures |
|
|
|
|
| |
|
|
|
|
Physical Safeguards |
|
|
|
|
| Assign
security responsibility |
|
|
|
|
| Does
the Security Officer have CISSP or equivalent training/experience? |
|
|
|
|
| Security
Officer issues an Annual Report |
|
|
|
|
| Media
controls |
|
|
|
|
| Access
control |
|
|
|
|
| Broad
definition of media; including: disks, tapes, CDs, printouts, source
documents, PDA’s, wireless devices, digital pagers |
|
|
|
|
| Written
policies in place concerning unauthorized software and data; e.g.,
unlicensed software, games, etc. |
|
|
|
|
| Enforcement
provisions in place to support the media control policies |
|
|
|
|
| Accountability
(tracking mechanism) |
|
|
|
|
| Data
backup |
|
|
|
|
| Data
storage |
|
|
|
|
| Disposal |
|
|
|
|
| Physical
access control (limited access) |
|
|
|
|
| Disaster
recovery |
|
|
|
|
| Emergency
mode operation |
|
|
|
|
| Equipment
control (into and out of site) |
|
|
|
|
| Facility
security plan |
|
|
|
|
| Procedures
for verifying access utilizations prior to physical access |
|
|
|
|
| Maintenance
records |
|
|
|
|
| Sign-in
for visitors and escort |
|
|
|
|
| Testing
and revision |
|
|
|
|
| Policy/guideline
on work station use |
|
|
|
|
| Secure
work station location |
|
|
|
|
| Security
awareness training |
|
|
|
|
| Other
Physical Safeguards |
|
|
|
|
| |
|
|
|
|
| Technical
Security Services |
|
|
|
|
| Access
control |
|
|
|
|
| Context-based
access |
|
|
|
|
| Encryption |
|
|
|
|
| Procedure
for emergency access |
|
|
|
|
| Role-based
access |
|
|
|
|
| User-based
access |
|
|
|
|
| Audit
controls |
|
|
|
|
| Authorization
Control |
|
|
|
|
| Role-based
access |
|
|
|
|
| User-based
access |
|
|
|
|
| Data
Authentication |
|
|
|
|
| Entity
Authentication |
|
|
|
|
| Automatic
logoff |
|
|
|
|
| Biometric |
|
|
|
|
| Password |
|
|
|
|
| PIN |
|
|
|
|
| Telephone
callback |
|
|
|
|
| Token |
|
|
|
|
| Unique
user identification |
|
|
|
|
| Other
Technical Security Services |
|
|
|
|
| |
|
|
|
|
| Technical
Security Mechanisms |
|
|
|
|
| Communications/network
controls |
|
|
|
|
| Access
controls |
|
|
|
|
| Alarm |
|
|
|
|
| Audit
trail |
|
|
|
|
| Encryption |
|
|
|
|
| Entity
authorization |
|
|
|
|
| Event
reporting |
|
|
|
|
| Integrity
controls |
|
|
|
|
| Message
authentication |
|
|
|
|
| Other
Technical Security Mechanisms |
|
|
|
|
| |
|
|
|
|
| Privacy |
|
|
|
|
| Uses
and disclosures: general |
|
|
|
|
| Use
or disclosure prohibited except as permitted or required |
|
|
|
|
| Minimum
necessary information |
|
|
|
|
| Uses
and disclosures subject to agreed upon restriction |
|
|
|
|
| Provision
for de-identified information |
|
|
|
|
| Business
Associates requirement to assure safeguards |
|
|
|
|
| Deceased
individuals receive same protection |
|
|
|
|
| Personal
representative treated as the individual specified |
|
|
|
|
| Support
alternative means or locations to receive confidential communications |
|
|
|
|
| Uses
and disclosures consistent with notice |
|
|
|
|
| Whistle
blower and work force member crime victim disclosure exemption |
|
|
|
|
| Uses
and disclosures: organizational requirements |
|
|
|
|
| Requirements
apply to the healthcare component of a hybrid entity affiliated
covered entities may designate themselves as a single covered entity |
|
|
|
|
| Business
Associate contract terms and enforcement to support permitted and
required uses and disclosures |
|
|
|
|
| Requirements
for group health plans that restrict disclosure to plan sponsor
supported by plan documents |
|
|
|
|
| Multiple
covered functions that apply to a combination of plan, provider,
and combination of plan, provider, and clearinghouse |
|
|
|
|
| Consent
for uses or disclosures to carry out treatment, payment, or healthcare
operations |
|
|
|
|
| Obtain
documentation of individual's consent |
|
|
|
|
| Managed
information disclosure in accordance with more restrictive of conflicting
consents |
|
|
|
|
| Utilization
and support for joint consent, where applicable |
|
|
|
|
| Uses
and disclosures for which authorization is required |
|
|
|
|
| Uses
and disclosures requiring an opportunity for individual to agree
or object |
|
|
|
|
| Maintain
records of restrictions on consenter authorization for facility
directories and others who ask for the individual by name |
|
|
|
|
| Disclosure
to family member or others identified by individual information
relevant to involvement and care or payment |
|
|
|
|
| Uses
of disclosures for which consent, authorization or opportunity to
agree or object is not required |
|
|
|
|
| De-identification
of protected health information |
|
|
|
|
| Disclosure
of minimum necessary information |
|
|
|
|
| Restrictions
on user disclosure of information for marketing |
|
|
|
|
| Prohibition
on the use of information for fundraising |
|
|
|
|
| Information
for underwriting |
|
|
|
|
| Verification
requirements for release prior to disclosure |
|
|
|
|
| Notice
of Privacy practices for protected health information |
|
|
|
|
| Individual's
right to notice of privacy practices |
|
|
|
|
| Rights
to request privacy protection for protected health information |
|
|
|
|
| Confidential
communications delivery by/at alternative means/sites |
|
|
|
|
| Access
of individuals to protected health information |
|
|
|
|
| Provision
to respond and document response to individuals right of access |
|
|
|
|
| Re-viewable
grounds for denial including written documentation for the basis
of the denial; review rights, if applicable; how to file a complaint;
and contact information |
|
|
|
|
| Review
of denial of access as a right of individual it must be performed
by an individual not directly involved in the denial |
|
|
|
|
| Amendment
of protected health information |
|
|
|
|
| Request
for amendment |
|
|
|
|
| Process
for accepting amendment |
|
|
|
|
| Process
for denying amendment |
|
|
|
|
| Accounting
of disclosures of protected health information |
|
|
|
|
| Content
of accounting: disclosures, dates, name of entity, etc. |
|
|
|
|
| Provision
of accounting within 60 days plus one 30 day delay |
|
|
|
|
| Documentation
of accounting |
|
|
|
|
| Administrative
requirements |
|
|
|
|
| Designation
of a privacy official |
|
|
|
|
| Privacy
training |
|
|
|
|
| Safeguards
to protect privacy of information |
|
|
|
|
| Process
for individuals to make complaints |
|
|
|
|
| Provision
and application sanctions |
|
|
|
|
| Mitigation
of harmful effect known of use or disclosure of information action |
|
|
|
|
| Policies
and procedures to comply with privacy regulation |
|
|
|
|
| Mechanism
to change policies and procedures to do changes in law written form
with documentation |
|
|
|
|
| Group
health plans exemption from some administrative standards |
|
|
|
|
| Effective
prior consents and authorizations |
|
|
|
|