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Marcus,
I addressed this identical issue with the Office of civil rights yesterday. They clearly stated the privacy rule does not mandate encryption (and I do not believe the security rule does either). Password protection of documents was considered a “reasonable” precaution vs. full blown encryption.
There has been much discussion on this topic and no consensus reached to my knowledge.
As a BA with many CE’s I am advising the CE’s of the privacy rule and informing them of the guidance I received from OCR.
Mike O’Gorman
-----Original Message-----
I would appreciate any suggestions on how a business associate should address the receipt of PHI from a covered entity that has been sent across an open network (without encryption) after the Privacy Rule is enforceable.
Thank you.
Marcus McCrory
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- Receipt of PHI Marcus E. McCrory
- RE: Receipt of PHI Oriol, Albert
- Re: Receipt of PHI Doug Webb
- RE: Receipt of PHI Deborah Campbell
- RE: Receipt of PHI Michael O'Gorman
- RE: Receipt of PHI Oriol, Albert
- RE: Receipt of PHI Sherry Neuman
