Termination Procedures Policy (UBIT HIPAA)

Category: HIPAA Security
Responsible Office: UBIT HIPAA Compliance
Responsible Executive: Vice President and Chief Information Officer (VPCIO)
Approved By (Name/Title): J. Brice Bible, VPCIO

CATEGORY: Administrative Safeguards
TYPE: Addressable Implementation Specification for Workforce Security Standard
CITATION: 45 CFR 164.308(a)(3)(ii)(C)

The University at Buffalo Information Technology (UBIT) operates as a covered entity as defined by the U.S. Department of Health and Human Services Office of Civil Rights. HIPAA Regulation Text 45 CFR Part 164.308(a)(3)(i) requires a covered entity to implement policies and procedures to ensure that all members of its workforce have appropriate access to ePHI, as provided under 164.308(a)(4), and to prevent those workforce members who do not have access under 164.308(a)(4) from obtaining access to ePHI.

UBIT implements policies and procedures for terminating access to ePHI under the following circumstances:

1. When UBIT workforce member’s employment ends.
2. When authorized access to ePHI access is no longer appropriate under UBIT’s Information Access Management Policy and Access Establishment and Modification Policy.

When required by determinations made as specified in Regulation Text 45 CFR Part 164.308 (a)(3)(ii)(B) Workforce Clearance Procedure Policy.

This policy applies to all UBIT workforce members.

Workforce members: Adhere to policies and procedures as written.

HIPAA Security and Privacy Officer: Responsible for overseeing the timely termination of access to ePHI systems when notified by the Director of Human Resources.

Compliance Officer: Participate in ensuring security of ePHI is effective and enforced, in conjunction with the HIPAA Security and Privacy Officer.

Chief of Staff: Notifies HIPAA Security and Privacy Officer when a workforce member’s authorized access to ePHI and ePHI Systems should be terminated.

Date Approved: 12/6/2017