Re: Logging Record Access in Transaction Systems

[James Kelly]

Title: Logging Record Access in Transaction Systems

Martin,   While I agree with you that the law does not seem to require full logging for TPO operations,  I as a vendor of payer software, feel that I must add it in to my system.  If an unauthorized access is made by a user, the only way to detect that would be a review of the audit logs. In addition, once it was determined that a user was in violation of policies and procedures, having the ability to query all accesses made by that user would be extremely beneficial.   In terms of Kris' questions regarding justification, I do not see how you can justify not turning it on.  I interpret the spirit of the law as giving patients the abilty to go to their insurer and ask "who has had access to my PHI and why?".  Without full logging, that question will be impossible to answer.   My two cents....     ----- Original Message ----- From: Martin Scholl To: [EMAIL PROTECTED] Sent: Monday, July 08, 2002 5:03 PM Subject: Re: Logging Record Access in Transaction Systems I am not logging at this point.  Though I keep it in mind in product design, I am way to busy with transaction sets.  I think logging is fine but a luxury I can't afford at this time.  Also logging can get very involved. Full logging, as you describe it, is a database task in itself. Develop reports, screens, access schemas and so forth. It is also my interpretation that you don't need logging within TPO (Treatment, Payment and Operations).  Only when access to PMI is outside of TPO, do you need to create a record. I think that for the majority of HIPAA covered entities full logging is overkill and not affordable. We shouldn't overlook the fact that healthcare costs in the US are unaffordable as it is. Logging does not add anything to the delivery of healthcare.   Martin Scholl Scholl Consulting Group, Inc. 301-924-5537 Tel 301-570-0139 Fax [EMAIL PROTECTED] www.SchollConsulting.com ----- Original Message ----- From: Owens, Kris To: [EMAIL PROTECTED] ; '[EMAIL PROTECTED]' Sent: Monday, July 08, 2002 1:04 PM Subject: Logging Record Access in Transaction Systems In our regional SNIP organization we are having a discussion about the logging of user's access to records in transaction systems and I would like to ask other organizations around the country what their plans are.  I appreciate your feedback. Definition: Full Logging: This is when a computer application (like a physician billing or claims processing system)  writes a record to a separate log or audit file every time a user adds, changes, deletes, or inquires a record.  The user access could occur either on-line using a screen, or through a batch process.  Generally, log records include, the operator id of the person that accessed the record, date and time the record was accessed, and a before and after image of the record, or the fields that were changed.  Full Logging is not  when an application stamps a record with Operator ID, date and time each time it is added, changed or deleted. Questions: 1.  Are your systems capable of doing "full logging"?    2.  Does your organization currently have "full logging" turned on?  For adds, changes, deletes and inquires?  Batch, on-line or both? 3.  What has been the impact to your overall system, has it impacted response time, disk resources etc? 4.  If you have logging turned on, do you have someone monitoring the log file?  Is this a full time job?  How are you using the log data? 5.  If your organization doesn't have full logging turned on do you plan on turning it on?  When? 6.  Will you have to upgrade your current system, customize it, or buy an additional product to get full logging capability?  Do you plan to? 7.  If you are currently doing full logging, or plan on doing it in the future, what is your justification for doing full logging?  What are your anticipated outcomes? 8.  If you are not doing full logging and do not plan on doing it in the future, what is your justification for not doing full logging? Kris Owens Senior IS Project Manager - HIPAA Project Presbyterian Healthcare Services Albuquerque, NM 505.923.8108 [EMAIL PROTECTED] "There is no meaning in isolation" ********************************************************************** To be removed from this list, send a message to: [EMAIL PROTECTED] Please note that it may take up to 72 hours to process your request. ================== The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. 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