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IO Datasphere has developed the HIPAA Privacy Accountability Tracking System
(HPATS) to help your organization comply with the HIPAA Privacy Rule. The HIPAA
Privacy Rule requires you to track the release of a patient's Protected Health
Information (PHI). It also requires you to act on requests to amend a patient's
medical record or requests to limit use and disclosure of PHI. HPATS assists
you in complying with these and other requirements of the regulation by
automating the compliance process within your organization. Key features of
HPATS allowing you to automate compliance for HIPAA Privacy include:
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Track PHI Disclosures by Date and Type of Disclosure |
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Track PHI Disclosures by Location and Department |
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Print the Accounting of Disclosures Report |
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Monitor Deadlines for Accounting of Disclosure Requests |
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Generate Letters (i.e. 30-Day Extension for Printing the Accounting of
Disclosure Report) |
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Track Authorizations |
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Track Complaints Related to HIPAA Privacy |
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Track Communications related to PHI |
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Automatic Notification of Special Communications Requirements |
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Customize Workflows According to Policies and Procedures |
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Print Standard Reports to Manage Workflow and PHI Disclosure Related
Information |
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Customize Workflows According to Policies and Procedures |
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Document Privacy Decisions |
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Account for Federal and State Privacy Regulations |
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HPATS can significantly reduce your costs to comply with the HIPAA Privacy Rule
and provide your staff with an effective automated solution. As a web-based
enterprise system, HPATS can be configured to easily maintain and retrieve all
information required for HIPAA privacy compliance, as well as other federal and
state privacy laws. HPATS can be the key to a cost effective HIPAA privacy
compliance solution.
IO Datasphere offers the HPATS Standard Version for a single organization
environment and the HPATS Enterprise Version for a multi-organization
environment such as a health system with multiple hospitals. Both versions
provide the same functionality for automating the tracking and reporting
required by the HIPAA Privacy Rule. However, the Enterprise Version allows
users to track and report information by selecting a single organization or by
selecting multiple organizations within the environment. All of the access to
information at any level (hospital, location, department, etc) is controlled
through user logins, assigned roles and privileges.
HPATS consists of four primary
components:
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Communications
- maintains all PHI related communications with external entities including
patients, personal representatives, healthcare providers, government agencies,
health plans and research companies. Communications captures the basic key
information (who, what, when and where) about a PHI related request
(disclosure, authorization, complaint, confidential communications, etc). This
includes simple requests for release of PHI to more complex requests such as
amending a medical record. Communications allows for grouping multiple
communications into a "Dialogue" to provide a complete history of ongoing
communications for any PHI item. Status tracking allows for easy review of
outstanding items or items approaching any deadline for processing.
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Authorizations
- maintains information for authorizations of PHI disclosures. Authorizations
provides for recording the key information about an authorization of PHI
disclosure including the requested PHI data, the requestor, whether
remuneration is involved and the authorized starting and ending dates.
Authorizations also tracks verification of the requestor and the approved,
pending or denied status of the request.
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Disclosures
- maintains information for PHI disclosures. Disclosures captures the details
of a PHI disclosure including a description of the PHI data, the receiving
organization's name, address and contact person, the date of disclosure and the
reason for the disclosure based on the disclosures allowed by HIPAA. Computer
generated disclosures can also be cross referenced to the actual data files
sent to external entities. An interface can be created to automatically load
these computer generated disclosures directly into HPATS.
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Data Exchanges
- maintains a list of the data exchanges (typically a computer program with a
specific output media such as CD-ROM or magnetic tape) used to transmit or
receive computer generated PHI information. This includes the decisions made to
verify the data exchange complies with HIPAA requirements such as "minimum
necessary", "authorization required" and "Treatment, Payment, Operations (TPO)
related". |
The following diagram depicts how HPATS interfaces with the external requests
for PHI data. Communications acts as a clearinghouse to capture key data and
link it to Authorizations or Disclosures. Users can easily enter and retrieve
information about a specific request or issue. Various reports can be generated
such as a listing of unauthorized PHI disclosures or a listing of
communications and decisions involved in a request to amend a medical record.
For tracking purposes, Disclosures can be linked to Data Exchanges. A Data
Exchange identifies the specific computer program or database query used to
create a PHI disclosure.

HPATS User Interface
HPATS is an easy to use web-based enterprise solution for automating the tasks
required for complying with the HIPAA Privacy Rule. Below is a sample HPATS
screen used to manage and retrieve information on PHI related communications.
Using drop down menus along with search (including partial key searches) and
sort capabilities, you can quickly find all of a patient's PHI related
communications records. The menu tabs at the top and navigation items on the
left allow users to easily move between the various components of HPATS. In
addition to the four primary components, the "Admin" component allows for
administration functions including configuration options and user security.
Pre-defined reports are also available through the "Reports" component. HPATS
also provides on-line Help screens and access to the HIPAA Privacy Rule and
related documents.

The following screen is used to enter details about a specific PHI Disclosure.
You can enter all of the information required by the HIPAA Privacy Rule (PHI
Disclosed, Disclosure Date, complete company and contact information for the
receiver of the PHI information, etc). In addition, HPATS allows you to
document additional information such as what was used to verify the identity of
the requestor, whether PHI information was archived using a document imaging
system and justification for the disclosure.

HPATS provides a complete audit tracking of decisions related to
disclosures. Each workflow and approval step is tracked as shown in the
Decisions section in the lower half of the screen. This is configurable to
match the specific workflow steps and decisions utilized in your organization.
Both summary and detailed history views are available. The summary view
displays the current status while the history view displays all decisions
regarding the disclosure. Users can view the details of any decision including
the justification and decision maker.
More HPATS Functionality
All of the data needed for compliance is maintained in several integrated
components that share key information. You can maintain a list of patients
along with their personal representatives. External entities involved with PHI
disclosures are also maintained including government agencies and business
partners. Similar to the screens and functionality for tracking and reporting
PHI Disclosures. HPATS provides the capability of tracking and reporting
Authorizations and other PHI related requests (i.e. Limited Use and Disclosure,
Confidential Communications, Suspensions of Accounting of Disclosures,
Complaints, Amendment of Medical Records, etc). Each component also has a
similar intuitive user interface making it easy for your staff to quickly learn
and use the system. Also, all of the items in the drop down menus are
configurable to customize the terminology, workflow and documented decisions to
meet your organization's policies and procedures.
Reporting
HPATS provides both standard reports and ad hoc reporting capabilities.
Standard reports include the Accounting of PHI Disclosures report with a date
range parameter to define the time period required along with the capability of
selecting what level(s) in the organization should be included. There are also
standard reports to list information by type of PHI related request, patient,
personal representative, or PHI disclosure recipient. You can use reporting
tools such as Crystal Report for custom analysis. Below are samples of an
Accounting of Disclosures Report and the report selection screen.


Role Based User Security
HPATS provides configurable user security to ensure only authorized employees
can access restricted information. Each user must be assigned access to
specific Roles and each Role has access to specific screens and pre-defined
functionality. In addition, the User is assigned User Organization Rights to
access data at any level in a multi-organization environment. A User can be
granted one or more data access rights at the hospital, location and/or
department levels. As shown in the example below, User security is easily
maintained by a system administrator using a point and click interface.

Beyond HIPAA
HPATS allows you to configure various options to extend the functionality and
effectiveness for your organization. This allows you to comply with other
federal and state privacy laws, as well as policies and procedures specific to
your organization. Specific tasks and related decisions can be defined and
tracked to help automate workflows and ensure all required processing has been
completed.
HIPAA Compliance
The HIPAA Privacy Rule mandates that covered entities manage and/or provide the
following functions:
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PHI Access |
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Access to an Accounting of Disclosures |
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Notice Acknowledgement Tracking |
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Amendment of PHI by patients |
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Confidential Communications |
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PHI Disclosure Tracking |
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Authorization of PHI Disclosures |
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Privacy Complaint Management |
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Due Diligence for Protecting PHI
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Requests for Limited Use and Disclosure of PHI |
Each item has its own parameters in terms of HIPAA compliance. For example, PHI
Access has a mandated requirement in terms of time allowed to fulfill a
request. An Accounting of Disclosures must cover a six year time period. If a
Request for Limited Use and Disclosure of PHI is approved, it impacts all
potential use of PHI even for TPO. These and many other mandated requirements
make it imperative for a covered entity to have an efficient and effective
solution. Using outdated systems or a manual approach will put an added burden
on your staff. With an automated approach such as HPATS, your organization can
reduce the workload of your staff, while ensuring compliance by tracking and
documenting all PHI related activities covered by the Privacy Rule.
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