Policies and 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:
Policies and Procedures and Documentation
TYPE: Standard 
CITATION: 45 CFR 164.316(a)

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 164.316(a) requires a covered entity to implement reasonable and appropriate policies and procedures to comply with the standards, implementation specifications, or other requirements of this subpart, taking into account those factors specified in 164.306(b)(2)(i),(ii),(iii) and (iv) [Flexibility of Approach]. This standard is not to be construed to permit or excuse an action that violates any other standard, implementation specification, or other requirements of this subpart. A covered entity may change its policies and procedures at any time, provided that the changes are documented and are implemented in accordance with this subpart.

UBIT implements reasonable and appropriate policies and procedures to comply with the HIPAA Security Regulations, Implementation Specifications, and/or other requirements as specified by the law. UBIT implements reasonable and appropriate policies and procedures to comply with the standards, implementation specifications, or other requirements of this subpart, taking into account those factors specified in 164.306(b)(2)(i),(ii),(iii) and (iv) [Flexibility of Approach]

This policy applies to all UBIT workforce members.

Workforce members: Adhere to all policies and procedures as written.

HIPAA Security and Privacy Officer: Ensures that UBIT implements reasonable and appropriate policies and procedures to comply with the HIPAA Security Regulations, Implementation Specifications, and/or other requirements as specified in 164.308(a)(2) - Assigned Security Responsibility, the HIPAA Security and Privacy Officer: 

1. In response to specific compliance directives from the Compliance Director, develop and disseminate appropriate security policies, procedures, and standards for the users and guardians of ePHI Systems.
2. Develop and maintain all documentation related to information security compliance of ePHI with federal, state and local laws, including HIPAA Privacy Regulations.
3. Consult with the Compliance Officer to confirm that UBIT’s information security policies, procedures, and controls support compliance with all applicable federal, state and local laws, including HIPAA Privacy Regulations.
   

Compliance Officer: Oversees UBIT implementation of reasonable and appropriate policies and procedures that comply with the HIPAA Security Regulations, Implementation Specifications, and/or other requirements as specified by the law.

Date Approved: 12/6/2017