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May 2013

HIPAA omnibus rule and stage 2 test organizational compliance

The words "meaningful" and "use" are undoubtedly on the lips of many a CIO as 2014 approaches and brings with it stage 2 of the federal EHR incentive programs, and especially in light of the recent omnibus HIPAA privacy and security rule. Final requirements outlining criteria for the certification of EHR technology for stage 2 meaningful use were published in September 2012. Meaningful use under the stage 1 criteria, which focused on data capturing and sharing in 2011 and 2012, must have been achieved before providers can move on to stage 2. Among the stage 2 criteria is specific detail about data encryption required for EHR certification. Core measure 7 of the stage 2 eligible hospital and critical access hospital (CAH) measures outlines several key areas: Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308(a)(1), including addressing the encryption/security of data stored in [certified EHR technology] CEHRT in accordance with requirements under 45 CFR 164.312 (a)(2)(iv) and 45 ...

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