Articles

Is there any harm in continous surveillance?

Comments Off 02 April 2013

For years, clients asked us what was the REAL cost of non-compliance (with HIPAA, PCI, etc).  Thankfully, Dr. Ponemon & his team put some real numbers to the cost of breaches.

 

Now, I’m constantly asked “what’s the harm in posting on facebook”, “using dropbox or google drive”, “buying Google glasses” or “why should we care about drones – video cameras watch us anyway”.

 

Prof. Neil Richards is diving head-on into this pool and he’s got some smart things to say.

From his abstract:

First, we must recognize that surveillance transcends the public-private divide. Even if we are ultimately more concerned with government surveillance, any solution must grapple with the complex relationships between government and corporate watchers. Second, we must recognize that secret surveillance is illegitimate, and prohibit the creation of any domestic surveillance programs whose existence is secret. Third, we should recognize that total surveillance is illegitimate and reject the idea that it is acceptable for the government to record all Internet activity without authorization. Fourth, we must recognize that surveillance is harmful. Surveillance menaces intellectual privacy and increases the risk of blackmail, coercion, and discrimination; accordingly, we must recognize surveillance as a harm in constitutional standing doctrine.

via The Dangers of Surveillance by Neil Richards :: SSRN.

 

Also look at what Bruce Schneier has to say about it at http://www.schneier.com/blog/archives/2013/03/the_dangers_of.html

 

Articles

Laptop, Smartphone – what’s the difference?

Comments Off 02 April 2013

What’s the difference between your laptop and your smartphone?

When it comes to information leakage, not much.

As the Wired article shows, cell phone wipes leave almost as much data behind as reformatting hard drives.

In both cases, the user thinks they have deleted data and purged traces.

In both cases, low cost tools can recover mountains of sensitive data.

Thinking about selling that old cell phone for cash?  Or donating it to charity?  You’d be better of getting it shredded…

 

Few things are more precious, intimate and personal than the data on your smartphone. It tracks your location and logs your calls. It’s your camera and your mobile banking device; in some cases it is a payment system in and of itself that knows what you bought and when and where and for how much. All of which explains why you wipe it before sending it off to a recycler or selling it on eBay, right? Problem is, even if you do everything right, there can still be lots of personal data left behind.

Simply restoring a phone to its factory settings won’t completely clear it of data. Even if you use the built-in tools to wipe it, when you go to sell your phone on Craigslist you may be selling all sorts of things along with it that are far more valuable — your name, birth date, Social Security number and home address, for example. You may inadvertently sell your old photos, nudes and all. The bottom line is, the stuff you thought you had gotten rid of is still there, if someone knows how to look.

“There are always artifacts left behind,” explains Lee Reiber,

via Break Out a Hammer: You’ll Never Believe the Data ‘Wiped’ Smartphones Store | Gadget Lab | Wired.com.

Articles

Peter Teffer interviews Raj Goel

Comments Off 02 April 2013

After the NCSC 2013 presentation, Peter Teffer interviewed me.

 

Here’s a (very poor) Google translation of his original Dutch article

If we do not ask, we will not get. Facebook, Google, Apple and other Internet and technology companies are only good for our privacy concerns, as consumers make on the barricades stand. “It is time to demand that your data are yours and not others,” said the American consultant Raj Goel, who recently gave a lecture in The Hague on social media and privacy.

Goel earns his money include giving such lectures – he has written a book that he wants to sell and companies hire him because he was known as a computer security expert. But that does not mean he does not believe in the importance of his message. “The battle for privacy is the next step in the civil rights struggle.”

It is not in the interest of Internet to our privacy and actually we do governments do not expect much. Only when consumers require smart phones and social networking really consider privacy, we will not thousands of times per month be spied, argues Goel.

Can we ordinary people large, powerful companies have reason to do what we want? “Yes,” says Goel. “Look at the history. 150 years ago we had no right to clean air or clean water and food. Only when someone like Upton Sinclair in 1905 the unhealthy conditions of the food described, the company said: enough, we want clean and healthy food. “

Cultural change is not impossible, emphasizes Goel. Forty years ago nobody read leaflets for drugs or labels of food. Nowadays. “If you are willing to five or ten minutes to devote to reading your food packaging and ask your doctor why certain medications are needed, then why not five minutes can take time to ask questions about the technology you use? “

Instead of just saying, wow, what a nice phone, we should also look at the privacy concerns of a product. “Make sure you’re more conscious consumer. Twenty years ago you had only eggs. Now you have free range eggs, organic eggs, free range. We have fair clothing and food. It is now time for honest technology. “

 

http://peterteffer.com/2013/03/29/strijd-voor-privacy-is-volgende-stap-van-burgerrechtenstrijd/

Articles

Michael Ahti – How China controls the internet

Comments Off 02 April 2013

The NCSC conference 2013 was an amazing event #1

 

Michael Ahti’s presentation on how China controls their internet (and how other countries are copying their model) was education and slightly frightening.

He clearly explains why the Chinese government encourages copycat sites and how Beijing uses citizens and the internet to control the regional Mandarins.

 

HIGHLY RECOMMENED!

 

Articles, Events

De Volkskrant – Beware The Little Sisters

Comments Off 02 April 2013

The NCSC conference 2013 was an amazing event #2

 

My presentation went over well – got lots of kudos and De Volkskrant selected it as one of their favorite presentations!

 

Read the 2 page article at the link below.

 

Everybody spies on everybody on the Internet. Your blogs, emails, tweets and Photos can [and will] always and everywhere be used against you ICT expert Raj Goel warns. He fights for privacy and self-determination rights of the computer user.

Beware The Little Sisters

By Wil Thijssen, Photo by An-Sofie Kesteleyn

via De Volkskrant – Beware The Little Sisters – Midtown, Manhattan, New York | Brainlink International, Inc..

Articles, News

New Filipino law makes liking on Facebook illegal

Comments Off 29 October 2012

Welcome to the Balkanization of the internet.

While I’m no fan of Facebook, laws like these will hamper freedom & civil rights.

I’ve always said that with Social Media, you need to worry about your friends – even if you do everything right, and your friends make a mistake or break the law, you may be found guilty by association.

This law turns that premise into reality.  If you ‘like’ a friend’s post, and that friend is found guilty of ["cybersex," identity theft, hacking, spamming, or pornography], then you are automatically guilty of the same.

 

From CBSnews.com

With more than 25 million Filipinos on Facebook and close to 10 million on Twitter, Filipinos rank among the top 10 users of both sites in the world.

But if you’re one of those who seldom think twice about “liking” a friend’s post on Facebook or re-tweeting someone else’s tweet, think again. Doing so in the Philippines may land you in jail.

On Sept. 12, President Benigno Aquino III signed into law the Cybercrime Prevention Act, which defines several new acts of crimes committed online, including, among others, “cybersex,” identity theft, hacking, spamming, and pornography.But while all that’s good, certain provisions of the law have millions of Filipinos up in arms – foremost of which is online libel.

“If you click ‘like,’ you can be sued, and if you share, you can also be sued,” said Sen. Teofisto Guingona III, one of the lawmakers who voted against the passage of the law.

“Even Mark Zuckerberg can be charged with cyber-libel,” the senator said.

via Facebook’s “like” may land Filipinos in jail – CBS News.

Articles, News

Prevent your kids from becomomg accidental porn stars

Comments Off 26 October 2012

Here’s another good reason to educate your kids and keep them off social media.

Parasite websites are popping up that exist solely to grab suggestive and sexually explicit photos of teens/tweens from Social Media and post them on adult websites.

This is Girls Gone Wild – Social media style.

 

Children and young people are posting thousands of sexually explicit images of themselves and their peers online, which are then being stolen by porn websites, according to a leading internet safety organisation.

A study by the Internet Watch Foundation (IWF) reveals that 88% of self-made sexual or suggestive images and videos posted by young people, often on social networking sites, are taken from their original online location and uploaded on to other websites.

Reams of sexually explicit images and videos are being uploaded by children and young people, the study found. During 47 hours, over a four-week period, a total of 12,224 images and videos were analysed and logged. The majority of these were then mined by “parasite websites” created for the sole purpose of displaying sexually explicit images and videos of young people.

via ‘Parasite’ porn websites stealing images and videos posted by young people | Technology | guardian.co.uk.

Articles, News

Who’s been tracking YOUR DNA?

Comments Off 26 October 2012

In the 1990′s we spent $ 2.5 BILLION to sequence the human genome.

Thanks to Moore’s law (computing power doubles every 18 months) and revolutionary breakthroughs in DNA sequencing, pretty soon, DNA sequencing will cost less than $ 1,000 per sample.

 

And several companies, including easyDNA are marketing their services to employers, spouses and lawyers.

So, who’s been tracking YOUR DNA? No one knows.

What rights do you have to data about your DNA?  None.

 

They’re called discreet DNA samples, and the Elk Grove, California, genetic-testing company easyDNA says it can handle many kinds, from toothpicks to tampons.Blood stains from bandages and tampons? Ship them in a paper envelope for paternity, ancestry or health testing. EasyDNA also welcomes cigarette butts two to four, dental floss “do not touch the floss with your fingers”, razor clippings, gum, toothpicks, licked stamps and used tissues if the more standard cheek swab or tube of saliva isn’t obtainable.If the availability of such services seems like an invitation to mischief or worse – imagine a discarded tissue from a prospective employee being tested to determine whether she’s at risk for an expensive disease, for instance – the Presidential Commission for the Study of Bioethical Issues agrees.

via Citing privacy concerns, U.S. panel urges end to secret DNA testing | Reuters.

Articles

Jeff Bezos, ebook Nobility. You, Kindle buyer, are serfs

Comments Off 22 October 2012

Amazon closed a Norwegian woman’s Amazon account AND DELETED all books off her Kindle for violating some secret Amazon policy.

 

Amazon will NOT disclose what policy she violated; nor restore her books; nor provide refunds for all the books that she purchased.

 

Moral of the story:  You do NOT own ebooks (or downloaded music, movies or games).  You are merely RENTING IT as a serfs from the digital landlord.  As a serf, the only rights you have are given to you by the landlord, and can be revoked at whim.

 

This isn’t the first time Amazon played digital bully.  In 2009, they settled a lawsuit for deleting 1984 from kindles (irony, thy name is Amazon!).  See http://www.pcworld.com/article/172953/amazon_kindle_1984_lawsuit.html

 

Amazon just closed her account and wiped her Kindle. Without notice. Without explanation. This is DRM at it’s worst.Linn travels a lot and therefore has, or should I say had, a lot of books on her Kindle, purchased from Amazon. Suddenly, her Kindle was wiped and her account was closed. Being convinced that something wrong had happened, she sent an e-mail to Amazon, asking for help. This was the answer:

Dear Linn [last name], My name is Michael Murphy and I represent Executive Customer Relations within Amazon.co.uk. One of our mandates is to address the most acute account and order problems, and in this capacity your account and orders have been brought to my attention. We have found your account is directly related to another which has been previously closed for abuse of our policies. As such, your Amazon.co.uk account has been closed and any open orders have been cancelled. Per our Conditions of Use which state in part: Amazon.co.uk and its affiliates reserve the right to refuse service, terminate accounts, remove or edit content, or cancel orders at their sole discretion. Please know that any attempt to open a new account will meet with the same action. You may direct any questions to me at resolution-uk@amazon.co.uk. Thank you for your attention to this email. Regards Michael Murphy Executive Customer Relations Amazon.co.uk

via Outlawed by Amazon DRM « Martin Bekkelund.

Articles

Woman arrested for outing an undercover cop on Facebook

Comments Off 18 October 2012

Cop posts his photo on Facebook.

Cop goes undercover, and a convict’s girlfriend outs him.

 

Umm…remind me again why cops need a facebook page?

 

Melissa Walthall

A Texas woman (Melissa Walthall) has been arrested and charged with a felony for posting a publicly available photograph of an undercover police officer to her Facebook profile, reports say.According to the Associated Press, Melissa Walthall, 30, of Mesquite, Tex., was arrested last week and charged with retaliation, a felony, for posting the photo.

via Melissa Walthall, Texas Woman, Arrested For Posting Photo Of Undercover Cop On Facebook.

Articles

Facebook outs most personal secrets

Comments Off 14 October 2012

Historically, I’ve spoken about the stupid/vain/dump things that users do on their Facebook profiles.

 

I’ve also warned about friending people.

 

Here’s an unfortunate case of social media revealing hidden data in VERY public manner.

From the Oct 14, 2012 Wall Street Journal

Bobbi Duncan desperately wanted her father not to know she is lesbian. Facebook told him anyway.

One evening last fall, the president of the Queer Chorus, a choir group she had recently joined, inadvertently exposed Ms. Duncan’s sexuality to her nearly 200 Facebook friends, including her father, by adding her to a Facebook Inc. discussion group. That night, Ms. Duncan’s father left vitriolic messages on her phone, demanding she renounce same-sex relationships, she says, and threatening to sever family ties.The 22-year-old cried all night on a friend’s couch. “I felt like someone had hit me in the stomach …

via When the Most Personal Secrets Get Outed on Facebook – WSJ.com.

Articles

The floppy isn’t dead – and old-fashion cut-n-paste defeats massive security

Comments Off 11 October 2012

A Canadian Sub-Lieutenant pled guilty to selling secrets to the Russians.

 

What is amusing, is how he defeated the complex technical controls present within the Canadian military.

 

He simply copied information to NOTEPAD and saved it on a FLOPPY.

Furthermore, when he got home, he composed EMAIL DRAFTS in a shared email account that the Russians had access to.

The latter technique is an Al-Qaeda favorite – use shared webmail accounts and transfer information via DRAFT messages.

 

How Delisle spied

Information presented at Delisle’s bail hearing detailed how Delisle would browse for material on the secure computer at Trinity, save it in the notepad feature, then transfer it to a floppy disk drive. He would take the floppy out of the secure computer, transfer it to an unsecure system and make a USB copy. After taking the USB home, he would access an email account given to him by the Russians and write in drafts. None of the material was ever transmitted, but the Russians could access the account and read the drafts.

it seems Canada didn’t learn from the American experience with army private Bradley Manning. Manning copied hundreds of thousands of diplomatic notes as well as Iraq and Afghanistan war logs, and then leaked them to WikiLeaks. “In the aftermath of that, the Americans had been warning all their allies, don’t get caught out in the way we did, don’t let someone steal information in the way Bradley Manning has done.”

In the wake of Manning’s arrest, President Barack Obama issued an executive order to strengthen his government’s computer security policies for all federal agencies.

Wark also points out that the other members of the “Five Eyes”, the U.S., the U.K., Australia and New Zealand, might have reason to be upset by Delisle’s spying. “What Delisle might have been able to tell the Russians that’s very, very damaging is how the communications systems themselves worked and the codes and processes they used to protect secrets. If the Russians have that, it’s a huge advantage for them, it’s a key into communications systems of not just Canada but all of our allies.”

via Spy Delisle’s guilty plea preserves Navy secrets – Politics – CBC News.

Articles, News

Schools are the new prisons – John Jay HS in Texas demands Students wear RFID or lose privileges

Comments Off 11 October 2012

Does the school administration (or the district, or the state) realize what a HUGE landmine they are burying in front of their faces?

A) Students are being trained in being permanently tracked

B) All the data that the RFID trackers will generate – how long will it be kept?  Who will analyze it?

C) Has anyone calculated the ediscovery & litigation costs for storing this data?

 

What are they SMOKING in Texas?  This is just insane…at what point do we declare Texas a failed state and provide it with some ADULT supervision?

 

John Jay High School in San Antoni, Texas, has launched a new program to increase attendance. The “Student Locator Project” requires students to wear their microchip-embedded school IDs around their necks at all times and have their location tracked and monitored.

And now, apparently, the students refusing to use the new IDs are not going to be allowed to vote for Homecoming court. One objector, Andrea Hernandez, has been told that if she continues to refuse the new IDs, she won’t be allowed to vote for homecoming royalty. This is, of course, deplorable, as the most vital, inalienable right of any high school student is the right to choose which popular kid is the MOST popular and will therefore rule over them.

via Students Refusing Tracking ID Cards Unable to Vote for Homecoming? | SMOSH.

Articles

HOW TO FILE A HEALTH INFORMATION PRIVACY COMPLAINT WITH THE OFFICE FOR CIVIL RIGHTS

Comments Off 10 August 2012

HOW TO FILE A HEALTH INFORMATION PRIVACY COMPLAINT WITH THE OFFICE FOR CIVIL RIGHTS

If you believe that a person, agency or organization covered under the HIPAA Privacy Rule (“a covered entity”) violated your (or someone else’s ) health information privacy rights or committed another violation of the Privacy Rule, you may file a complaint with the Office for Civil Rights (OCR). OCR has authority to receive and investigate complaints against covered entities related to the Privacy Rule. A covered entity is a health plan, health care clearinghouse, and any health care provider who conducts certain health care transactions electronically. For more information about the Privacy Rule, please look at our responses to Frequently Asked Questions (FAQs) and our Privacy Guidance. (See the web link near the bottom of this form.)

Complaints to the Office for Civil Rights must: (1) Be filed in writing, either on paper or electronically; (2) name the entity that is the subject of the complaint and describe the acts or omissions believed to be in violation of the applicable requirements of the Privacy Rule; and (3) be filed within 180 days of when you knew that the act or omission complained of occurred. OCR may extend the 180-day period if you can show “good cause.” Any alleged violation must have occurred on or after April 14, 2003 (on or after April 14, 2005 for small health plans), for OCR to have authority to investigate.

Anyone can file written complaints with OCR by mail, fax, or email. If you need help filing a complaint or have a question about the complaint form, please call this OCR toll free number: 1-800-368-1019. OCR has ten regional offices, and each regional office covers certain states. You should send your complaint to the appropriate OCR Regional Office, based on the region where the alleged violation took place. Use the OCR Regions list at the end of this Fact Sheet, or you can look at the regional office map to help you determine where to send your complaint. Complaints should be sent to the attention off the appropriate OCR Regional Manager.

You can submit your complaint in any written format. We recommend that you use the OCR Health Information Privacy Complaint Form which can be found on our web site or at an OCR Regional office. If you prefer, you may submit a written complaint in your own format. Be sure to include the following information in your written complaint:

Your name, full address, home and work telephone numbers, email address.

If you are filing a complaint on someone’s behalf, also provide the name of the person on whose behalf you are filing.

Name, full address and phone of the person, agency or organization you believe violated your (or someone else’s) health information privacy rights or committed another violation of the Privacy Rule.

Briefly describe what happened. How, why, and when do believe your (or someone else’s) health information privacy rights were violated, or the Privacy Rule otherwise was violated?

Any other relevant information.

Please sign your name and date your letter.

The following information is optional:

Do you need special accommodations for us to communicate with you about this complaint?

If we cannot reach you directly, is there someone else we can contact to help us reach you?

Have you filed your complaint somewhere else?

via HIPAA News, Regulations, Compliance, Complaints, Penalties, Privacy and Security.

Articles

HIPAA Checklist

Comments Off 10 August 2012

HIPAA Checklist

 

# Question Not
Started
In
Process

Completed

Awareness & Education
1 Has your organization had any
Awareness Education on HIPAA Regulations and Compliance?
     
2 Do you monitor or receive
automated information regarding changes in HIPAA regulations
     

Project Planning
3 Have you selected a Project
Manager and Project Team for your HIPAA Project?
     
4 Have you created a Project
Plan?
     

Electronic Transactions
5 Have you applied for the ACSA
Electronic Transaction extension for your organization?
     
6 Have you completed an inventory of all information systems and work flow processes with regard to Electronic Transactions?      
7 Have you compiled a list of
vendors, health plans, business associates and trading partners?
     
8 Have you gathered, reviewed and
compared your current billing forms, policies, and procedures to the HIPAA Electronic Claims Transaction and Code Set regulations?
     

Privacy
9 Has your organization designated an Information Privacy and Security Officer as required by HIPAA?      
10 Have you developed a Notice of
Information Practices to post in your office and distribute to each patient?
     
11 Have you gathered, reviewed and
compared your current forms, policies, and procedures to the HIPAA Privacy Regulations and State Privacy Regulations?
     
12 Have you developed policies and
procedures that meet the needs of your Human Resources Department with regard to Privacy requirements for the
protection of health information of your staff?
     
13 Have you developed processes
for documenting, retaining, distributing and discarding Protected Health Information (PHI) as required by HIPAA?
     
14 Have you developed processes
for receiving, investigating and documenting individual complaints?
     
15 Have you developed or revised
current consent forms for patients in line with HIPAA regulations?
     
16 Do you have all forms that must
be read and signed by patients in languages appropriate to their
culture?
     

Security
17 Has your organization completed
a Security Evaluation on the information systems used in conjunction with maintaining your current and future Protected Health Information?
     
18 Does your organization have virus checking software, firewalls and operating systems that provide encryption and other security measures?      
19 Does your organization perform back-ups of your data daily?      
20 Does your organization have a Disaster Recovery and Contingency Plan to meet the HIPAA Security Standards?      
21 Has you organization developed security policies and procedures with regard to confidentiality statements, individually identifying information system users,
passwords, automatic logoff, acceptable use, e-mail, internet usage, authentication of workstations, monitoring and documenting unauthorized access, audit trails of users, sanctions for misuse or disclosure and termination checklists?
     
22 Has your organization provided for the overall physical security of your  information systems, facility, staff, and medical records?      
23 Has your organization developed job descriptions for HIPAA required positions and all other positions in your organization?      

National Identifiers
24 Have you located, printed and read the Proposed Regulations for National Identifiers to include National Provider Identifier and National Payer Identifier, National Employer Identifier?      

General Information
25 Have you developed a comprehensive training program for your organizations staff (both present and future) covering all HIPAA standards to include responsibilities and penalties for  non-compliance?      
26 Does your organization have a Compliance Officer and General  Compliance Plan to cover such things as fraud and abuse, codes of conduct, whistle-blower suits, auditing and monitoring, disciplinary standards and
personnel issues, responding to problems, investigations and corrective actions?
     

 

 

Articles, News

Hospital must implement revised policies for telephone messages

Comments Off 10 August 2012

Hospital Implements New Minimum Necessary Polices for Telephone Messages

Covered Entity: General Hospital

Issue: Minimum Necessary; Confidential Communications

A hospital employee did not observe minimum necessary requirements when she left a telephone message with the daughter of a patient that detailed both her medical condition and treatment plan. An OCR investigation also indicated that the confidential communications requirements were not followed, as the employee left the message at the patient’s home telephone number, despite the patient’s instructions to contact her through her work number. To resolve the issues in this case, the hospital developed and implemented several new procedures. One addressed the issue of minimum necessary information in telephone message content. Employees were trained to provide only the minimum necessary information in messages, and were given specific direction as to what information could be left in a message. Employees also were trained to review registration information for patient contact directives regarding leaving messages. The new procedures were incorporated into the standard staff privacy training, both as part of a refresher series and mandatory yearly compliance training.

via All Case Examples.

Articles, News

Private Practice banned from charging excessive medical records fee

Comments Off 10 August 2012

Entity Rescinds Improper Charges for Medical Record Copies to Reflect Reasonable, Cost-Based Fees

Covered Entity: Private Practice

Issue: Access

A patient alleged that a covered entity failed to provide him access to his medical records. After OCR notified the entity of the allegation, the entity released the complainant’s medical records but also billed him $100.00 for a “records review fee” as well as an administrative fee. The Privacy Rule permits the imposition of a reasonable cost-based fee that includes only the cost of copying and postage and preparing an explanation or summary if agreed to by the individual. To resolve this matter, the covered entity refunded the $100.00 “records review fee.”

via All Case Examples.

Articles, News

Private Practice required to change waiting room layout

Comments Off 10 August 2012

Private Practice Implements Safeguards for Waiting Rooms

Covered Entity: Private Practice

Issue: Safeguards; Impermissible Uses and Disclosures

A staff member of a medical practice discussed HIV testing procedures with a patient in the waiting room, thereby disclosing PHI to several other individuals. Also, computer screens displaying patient information were easily visible to patients. Among other corrective actions to resolve the specific issues in the case, OCR required the provider to develop and implement policies and procedures regarding appropriate administrative and physical safeguards related to the communication of PHI. The practice trained all staff on the newly developed policies and procedures. In addition, OCR required the practice to reposition its computer monitors to prevent patients from viewing information on the screens, and the practice installed computer monitor privacy screens to prevent impermissible disclosures.

via All Case Examples.

Articles, News

Pharmacy required to implement BAA with law firm

Comments Off 10 August 2012

Pharmacy Chain Enters into Business Associate Agreement with Law Firm

Covered Entity: Pharmacy Chain

Issue: Impermissible Uses and Disclosures; Business Associates

A complaint alleged that a law firm working on behalf of a pharmacy chain in an administrative proceeding impermissibly disclosed the PHI of a customer of the pharmacy chain. OCR investigated the allegation and found no evidence that the law firm had impermissibly disclosed the customer’s PHI. However, the investigation revealed that the pharmacy chain and the law firm had not entered into a Business Associate Agreement, as required by the Privacy Rule to ensure that PHI is appropriately safeguarded. Without a properly executed agreement, a covered entity may not disclose PHI to its law firm. To resolve the matter, OCR required the pharmacy chain and the law firm to enter into a business associate agreement.

via All Case Examples.

Articles, News

Radiologist sanctioned for relying on incorrect billing information

Comments Off 10 August 2012

Radiologist Revises Process for Workers Compensation Disclosures

Covered Entity: Health Care Provider

Issue: Impermissible Uses and Disclosures

A radiology practice that interpreted a hospital patient’s imaging tests submitted a worker’s compensation claim to the patient’s employer. The claim included the patient’s test results. However, the patient was not covered by worker’s compensation and had not identified worker’s compensation as responsible for payment. OCR’s investigation revealed that the radiology practice had relied upon incorrect billing information from the treating hospital in submitting the claim. Among other corrective actions to resolve the specific issues in the case, the practice apologized to the patient and sanctioned the employee responsible for the incident; trained all billing and coding staff on appropriate insurance claims submission; and revised its policies and procedures to require a specific request from worker’s compensation carriers before submitting test results to them.

via All Case Examples.

What to teach your kids about Social Media

Comments

Thank you for sharing your presentation. Richard Collier Methodist. Leading Medicine. (Richard Collier)

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