The preamble to the final Security Rule (page 8334) says that covered entities ..."must comply with the requirements of this final rule by April 21, 2005." In section 164.318 of the Security Rule itself (page 8380) the compliance date is specified as "...no later than April 20, 2005." If you read these statements carefully, you'll realize that the wording is slightly different. One says "by" and the other says "no later than". It's the same point in time, i.e., "not later than April 20" is the same as saying "by April 21".
You wouldn't believe how many questions I've fielded on this matter. >>> "Robinson, Laura" <[EMAIL PROTECTED]> 03/20/03 12:07PM >>> Regarding the Security deadline, I also thought it was April 21 (read this somewhere) but I think the deadline is actually April 20, 2005, as stated in final rule section 164.318. Just a detail... -----Original Message----- From: Vikas Budhiraja [mailto:[EMAIL PROTECTED] Sent: Thursday, March 20, 2003 8:32 AM To: WEDI SNIP Privacy Workgroup List Subject: Privacy vs. Security Compliance The covered entities have time till April 21, 2005 to comply with the final Security regulations. However, Privacy compliance deadline is April 14, 2003. Now, Privacy compliance also requires some safeguards that are actually defined in the Security regulation. How do we deal with this paradox? (Privacy protection does not have much meaning without Security being in place). I am trying to come up with a list of minimum safeguards that can be practically put in place by April 14, 2003 - such as - Physical access control and workstation security. I wanted to see what others are doing in this regard and if they have a "minimum necessary" security compliance list. Regards, Vikas --- 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/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org --- 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/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org --- 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/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
