Yours truly took a long needed mini-vacation last weekend to Yosemite National Park – my first-ever visit to spectacular Yosemite. My 55th birthday was last weekend, and the idea was to get away from the pressures, the meetings, the calls — away from HIPAA — for a few days to clear my head.

So there I was, driving into Yosemite valley in the rental car, awestruck at the raw beauty, the magnificence, the splendor… the ARRA (American Recovery and Reinvestment Act)?

Yes readers, in the midst of the Yosemite wilderness, imagine my surprise when I rounded a curve in the steep road and saw this…

ARRA at Work in Yosemite

I was dramatically reminded, as people in the HIPAA world easily forget, that the ARRA is accomplishing much more than expanding HIPAA. There, in the wilds of Yosemite, was the ARRA, funding road and infrastructure improvements to one our greatest national parks!

So the next time somebody asks you what the ARRA has achieved, point to HIPAA expansion, breach notifications, tougher sanctions… and yes, Yosemite!

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Various types of online social networks are apparently the “next big thing” in relationships, and they are changing the nature of human interactions. But social networks also pose a major threat to the PHI Covered Entities (CEs) and Business Associates (BAs) are entrusted with.

Peer-to-Peer Networks Expose PHI

Researchers at Dartmouth College probed peer-to-peer (P2P) networks recently to try and determine the extent to which private medical data is exposed on these networks. Over a two-week period, what they found was shocking…

• A spreadsheet from an AIDS clinic with 232 client names,including Social Security numbers, addresses and birth dates.
• Databases for a hospital system that contained detailed information on more than 20,000 patients, including Social Security numbers, contact details, and insurance records, along with diagnosis information.
• A 1,718-page document from a medical testing laboratory containing patient Social Security numbers, insurance information, and treatment codes for thousands of patients.
• More than 350 megabytes of sensitive patient reports from a group of anesthesiologists.

According to the article above…

In all, researchers found hundreds of documents revealing sensitive information on tens of thousands of patients.

The full Dartmouth report is also available as a PDF download (858 Kb).

Personal Social Networks Are Another PHI Threat

P2P networks are different creatures than what are sometimes called “personal social networks” (PSNs). Personal social networks include sites like MySpace and Facebook, where people go (usually) to meet and fraternize with other like-minded people.

Exposure of PHI on personal social networks has already been identified as a growing problem. Increasingly, people are use their MySpace, Facebook, and other social network pages to vent their gripes about their doctors and their medical care.

So here are some critical questions you should consider…

• Do you know if you or your practice has been mentioned (positively or negatively) in any of your patients’ social network pages?
• What would you do if you found your patients’ PHI exposed on such sites? What could you do?
• How extensively are your employees using social networks? Are patients being discussed? Is any PHI being disclosed?
• Do you have a written policy regarding personal social networks, P2P networks, and similar online social channels?

It’s later than you think on this front. Your patients, vendors, and the crooks out there are likely farther along than you are in dealing with these issues. The HIPAA implications are enormous, especially with the ARRA’s new Breach Notification rule kicking in shortly.

Overall, the most important question you need to answer is:

Where’s your PHI?

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