Rohit,

The most cost-effective way to handle these requirements is to get your
HIPPA auditor drunk nightly.

I'm being partially serious here because these and other HIPPA requirements
are:

(1) Technically ambiguous
(2) Often in conflict with other HIPPA requirements
(3) Impossible to achieve cost effectively

For example, there are HIPPA access control requirements that demand that
you only give doctors access to transmit patient data in a minimal way; only
transmitting data needed for a diagnosis. Good luck coding that. It's also
bad medicine.

And now, let me leave you with a few lyrics from the Bon Jovi song "bad
medicine". He was singing about medical software, I'm fairly sure:

"I ain't got a fever got a permanent disease
And it'll take more than a doctor to prescribe a remedy
And I got lots of money but it isn't what I need
Gonna take more than a shot to get this poison outta me
And I got all the symptoms, count 'em 1, 2, 3"

;)
Jim Manico

On Apr 26, 2011, at 2:35 AM, Rohit Sethi <rkli...@gmail.com> wrote:

Hi all,

Has anyone had to deal with the following HIPAA compliance requirements
within a custom application before:



§164.312(c)(2)

Implement electronic mechanisms to corroborate that electronic protected
health information has not been altered or destroyed in an unauthorized
manner.



§164.312(e)(2)(i)

Implement security measures to ensure that electronically transmitted
electronic protected health information is not improperly modified without
detection until disposed of.


How have you actually implemented these controls in applications? Have you
used a third party tool to do this? Does §164.312(c)(2) simply boil down to
sufficient access control?

-- 
Rohit Sethi
SD Elements
http://www.sdelements.com
twitter: rksethi

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