Third-party Relationships and Your Confidential Data
Increased use of third-party vendors for applications and data processing services is a business model that is likely to continue, especially as organizations find it necessary to focus limited resources on core organizational objectives and contract out support services. Be sure to read the latest AHIA and Grant Thornton LLP White Paper: Third-party Relationships and Your Confidential Data to learn about the role internal audit should play in assuring risks are recognized and managed appropriately.
As the volume of electronic medical data has grown, so has the number of third-party custodians that handle it. Organizations increasingly rely on third parties for infrastructure, managed applications and data management. Navigating the changing rules governing these third parties has become more complex. Organizations now face theadditional responsibilities and challenges of useraccess management, change management anddata stewardship, even though they don't ownthe structure or directly manage the resourcesinvolved. The risk of these relationships is significant: third parties have been responsible for almost half of all data breaches.
Compounding these challenges are new federal requirements and continuously evolving state requirements for managing electronic protected health information (ePHI). Important changes that take effect Sept. 23, 2013, in the Health Insurance Portability and Accountability Act (HIPAA) Omnibus Rule broaden the definition of a business associate, set new limits on how data may be used, redefine what constitutes a breach and establish new civil penalties for violation
We wish to thank the following individuals, without whom this resource would not be available:
Grant Thornton Project Team:
Principal, National Leader, Health Care IT Advisory Services
Business Development Director
National Marketing Manager, Health Care
AHIA White Paper Subcommittee:
Mark Eddy, CPA
Michael Fabrizius, CPA
Carolinas HealthCare System
Linda McKee, CPA (Board Liaison)
Glen Mueller, CPA (Chair)
Mark Ruppert, CPA
Cedars-Sinai Health System
Debi Weatherford, CPA
We appreciate the support of numerous colleagues who assisted in the review of this document.
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