August 19, 2013 Mac McMillan
There seems to still be a fair amount of discussion around what makes a vendor a business associate. This is actually troubling when you consider that we are about 30 days away from enforcement of the new rules.
April 8, 2013 Mac McMillan
Under the Omnibus Rule, breach notification received more than just a face-lift. The new rule went into effect on March 26, 2013 so Covered Entities and Business Associates alike should have updated their incident response and notification procedures in preparation.
February 20, 2013 Mac McMillan
Lately I’ve seen an uptick in the number of articles and posts wanting to blame or point the finger at workforce members for the breach activity we continue to see plague healthcare. Statements like, we need to focus more on the workforce or workforce training needs to be enhanced. Don’t get me wrong, I’m not suggesting that a fair amount of the responsibility does not lie with workforce members, but I would suggest that they are a symptom or the manifestation of the problem.