I'm also very interested in hearing how other entities are dealing with
this, in lieu of the security rules being finalized.  One policy I've been
looking at/wrestling with for a long time now is the HCFA Internet Security
Policy, issued November 1998 - this policy specifically says that in Section
4 -- "HCFA has prohibited the use of the Internet for the transmission of
all HCFA Privacy Act-protected and other sensitive HCFA information by its
components and Medicare/Medicaid partners, as well as other entities
authorized to use this data. ...............(Section 5)It is permissible to
use the Internet for transmission of HCFA Privacy Act-protected and/or other
sensitive HCFA information, as long as an acceptable method of encryption is
utilized to provide for confidentiality and integrity of this data, ......."

 
We are a Health Plan that only administers Medicaid, and we have a policy
that states member information can be shared via email only internally to
our own workforce because it isn't going through the internet.  Our policy
states we won't use the Internet to pass member information to our business
associates because no one (that I've been able to find) has internet
security good enough to meet this policy.  
 
How are other entities that deal with Medicaid and Medicare member data
using the internet now?  Our business associates really want to use the
Internet for all kinds of business processes.
Tomese Buthod 
Director, Compliance/Projects 
Passport Health Plan 
502-585-7925 
502-585-6060 (fax) 

-----Original Message-----
From: Bill Bernath [mailto:[EMAIL PROTECTED]]
Sent: Monday, April 08, 2002 4:33 PM
To: [EMAIL PROTECTED]
Subject: Securing E-mail




We've talked about our needs to provide reasonable protection for verbal,
paper and electronic PHI content.  Another critter we need to wrestle with
is how do we handle at least two families of e-mail?  One set is that which
is used in a legitimate exchange between ourselves and our business
associates and providers.  These audiences will likely have varied levels of
security sophistication at their end.  The second group is the internal
'use' by the gossip hotline, where members of the workforce are sharing
sensitive stuff with their pals, because they can.....  Other than having a
strong personal accountability policy, has anyone considered other
solutions?  Thx - b
 
Bill Bernath
Blue Cross Blue Shield of North Carolina 
Privacy Office
(919) 765-7006
[EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]> 


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