[optimal] Re: HIPAA Security initiative

  • From: James Strong <jamesdstrong@xxxxxxxxx>
  • To: optimal@xxxxxxxxxxxxx
  • Date: Fri, 17 Feb 2012 09:15:04 -0500

One thing to keep in mind here is that DICOM and HIPAA are two completely
different animals and don't have much to do with one another. An instrument
being DICOM compliant doesn't mean it will be HIPAA-fied.

DICOM is a "standardised" data structure that means an instrument that is
DICOM compliant "should" be able to exchange data with other
DICOM compliant systems.  Be aware that DICOM isn't a silver bullet for
data/system integration; there are varying "flavors" or dialects of DICOM.
If the 2 pieces don't speak the same dialect then things get much more
complicated.

HIPAA deals with keeping Protected Health Information safe and has multiple
facets.  Some of which are as simple as Password protecting systems that
contain PHI, individual log-ins to such systems, and audit trails for data
access i.e. who is looking at what data.

While DICOM-izing an instrument may ultimately push your data into a HIPAA
compliant system, it doesn't make the instrument itself or the data it can
access HIPAA compliant.

If it were my project, i'd ask my HIPAA expert to come to clinic and look
at the instrument with me so they understand how it is used and then
generate a specific list of concerns and pose that to the vendor.

That said, i think this is a GREAT thread and am also VERY curious if
someone out there has gone thru the process from the perspective of a large
institutional hospital, because it's going to be very
interesting. Unfortunately i don't know that there will be one absolute
answer; i think the way HIPAA has been constructed, it leaves much open to
the interpretation.

j-

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