There is no requirement to have multiple policies as long as your Privacy
Policy covers all aspects of the Privacy Regulation that affect your
organization. However, from a convenience and maintenance viewpoint it may be
better to have a set of policies (10-15) and detailed procedures for
implementing those policies.
Vikas Budhiraja, Ph.D.
Infotech Global, Inc.
(732) 271-0600 ext. 125
-----Original Message-----
From: BARRIS, BARBARA [mailto:[EMAIL PROTECTED]]
Sent: Thursday, September 12, 2002 2:02 PM
To: '[EMAIL PROTECTED]'
Subject: Privacy Policies
From: BARRIS, BARBARA [mailto:[EMAIL PROTECTED]]
Sent: Thursday, September 12, 2002 2:02 PM
To: '[EMAIL PROTECTED]'
Subject: Privacy Policies
We are a health plan. Our Administration Department is stating that we can have one general, generic policy for the Privacy Rule and use procedures to implement the standards, implementation specifications, and requirements. I disagree. Everything I have read and all the conferences I have attended have stated that we need separate policies and procedures. Does anyone agree that we could meet the Privacy Rule requirements with one policy and many procedures or does the Privacy Rule require multiple policies and procedures? I admit that I am not a very good at arguing my viewpoint, and would appreciate references supporting the argument that we need multiple policies and procedures. Thanks.
Barbara Barris
HIPAA Project Manager
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