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HIPAA Compliance Readiness Statement
Overview
The Health Insurance Portability and Accountability Act of 1996 Public Law 104-191 ("HIPAA") was passed by Congress with the intend to reform the insurance market and simplify health care administrative. Specifically the HIPAA Administrative Simplification is aimed at reducing the costs and administrative burdens of health care by adopting and requiring the use of standardized, electronic transmission of administrative and financial transactions. The Administrative Simplification also imposes requirement for the protection of private health information.
As a covered entity, as defined by HIPAA sections 160.102 and 160.103, Office Ally is dedicated to attain HIPAA compliance by the deadlines as provided by the regulation.
Furthermore, as a clearinghouse, Office Ally welcomes the opportunity to play a strategic role in the implementation of HIPAA and to assist providers of all sizes and all levels of technology in their efforts to reach and sustain HIPAA compliance.
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Definitions
Covered Entity
45CFR160.103
Covered entity means one of the following:
- A health plan.
- A health care clearinghouse.
- A health care provider who transmits any health
information in electronic form in connection with a transaction covered by
this subchapter.
Health Care Clearinghouse
45CFR160.103
Health care clearinghouse means a public or private entity that does either of the following (Entities, including but not limited to, billing services, repricing companies, community health management information systems or community health information systems, and "value-added" networks and switches are health care clearinghouses for purposes of this subchapter if they perform these functions.):
- Processes or facilitates the processing of information received from another entity in a nonstandard format or containing nonstandard data content into standard data elements or a standard transaction.
- Receives a standard transaction from another entity
and processes or facilitates the processing of information into nonstandard
format or nonstandard data content for a receiving entity.
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Compliance deadlines for the Administrative Simplification
| Submission of compliance extension form
for Electronic Health Care Transactions and Code Sets |
October 15, 2002 |
| Electronic Health Care Transactions and
Code Sets compliance date - except for covered entities who have filed
the extension and small health plans |
October 16, 2002 |
| Privacy - all covered entities to the
exception of small health plans |
April 14, 2003 |
| Electronic Health Care Transactions and
Code Sets Testing - all covered entities must have started software
and systems testing |
April 16, 2003 |
| Electronic Health Care Transactions and
Code Sets - all covered entities who had filed for an extension by
October 15, 2003 and all small health plans |
October 16, 2003 |
| Privacy - small health plans |
April 14, 2004 |
| Employer Identifier Standard - all covered
entities except small health plans |
July 30, 2004 |
| Employer Identifier Standard - small health
plan |
August 1, 2005 |
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Office Ally HIPAA Compliance Program
Office Ally has developed a comprehensive HIPAA Compliance Program in order to
ensure compliance by the deadlines. This program addresses the Privacy rule as
well as the Security Rule (i.e., Administrative, Physical Safeguards, Technical
Security Measures and Technical Security Mechanisms). The program is presented
below in its various stages of completion:
| Appointment of HIPAA Compliance Officer |
January 1, 2003 |
| Filing of Extension form for Electronic Health Care Transactions
and Code Sets |
October 15, 2003 |
| Development of training material |
January 13, 2003 |
| Gap Analysis |
March 14, 2003 |
| Disaster Recovery Plan strategy |
April 14, 2004 |
| Development of translation tools from non-compliant to compliant
transactions for all formats currently supported |
April 14, 2003 |
| Development of translation tools from compliant to non-compliant
transactions for all formats currently supported |
April 14, 2003 |
| Testing with Third Party for ANSI format |
October 16, 2002 |
| Training session for Office Ally personnel |
October 15, 2003 |
| Development of Policies and Procedures |
April 14, 2004 |
| Business Associate Agreement |
October 15, 2003 |
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Security and PHI
Protected Health Information (PHI)
45CFR164.501
Protected health information means individually identifiable health information:
- Except as provided in paragraph (2) of this definition, that is:
- Transmitted by electronic media;
- Maintained in any medium described in the definition of electronic media
at §162.103 of this subchapter; or
- Transmitted or maintained in any other form or
medium.
- Protected health information excludes individually identifiable health information
in:
- Education records covered by the Family Educational Rights and Privacy
Act, as amended, 20 U.S.C. 1232g;
- Records described at 20 U.S.C. 1232g(a)(4)(B)(iv); and
- Employment records held by a covered entity in its
role as employer.
To ensure protection of PHI, we have built and implemented our security solution
with Internet Explorer 5.0+, Windows 2000, SSL, and a proprietary component (AspEncrypt).
This tight integration allows us to provide:
- Authenticated Logon.
- Control over Access/Privileges to personal information
- (SIDs) Personal Security Identifiers
- Secure end to end Transmission of information
- File integrity
Internet Explorer gives us a secure client-side environment to work in and
thru an authenticated logon, allows only valid users to access our services.
With windows 2000 your information is specially protected through industry
standard security mechanisms and policies like the strict 'Principle of Least
Possible Privilege' that governs clients and employees access to company systems
and information. We have incorporates SSL to provide a secure end-to-end
Transmission of data from the clients machine to our network servers. And, to
ensure the users identity, if they are inactive for an extended period of time,
the site will log them off and he or she will need to reenter their Username and
Password.
Data is kept secure and private. We secure data files by encrypting and storing
them on our servers. By encrypting files, we have significantly reduced the risk
of unwanted eyes peering though data. Only our proprietary components have the
ability decipher the encrypted data. This encryption also provides data integrity,
which prevents any malicious attempt to manipulate the data that we have received
from the submitter. As an added measure for non-repudiation, we track and log
all user and employee transaction via (SIDs) Security Identifiers. Each user and
employee is issued a SID, which uniquely identifies him or her in our system.
It is the policy of the Office Ally to encrypt the transmission of all personal
or financial Web-based information that is transmitted between our site and your
browser. The security standard SSL (Secure Sockets Layer) is used to implement
this. SSL is the leading standard for securing World Wide Web transmissions.
The Office Ally website is certified by DigiCert Inc. Users can verify the validity
of the certification on the website:
(img)
Valid Certificate
Authentic Sites use DigiCert Global CA SSL Web Server Certificates to offer secure communications
by encrypting all data to and from the site. DigiCert Inc has checked and verified
the company registration documents and the site's registered domain name.
This information is included in the SSL certificate that we issue. This
enables you to check the site's validity yourself. Always check a site's
certificate before entering any sensitive information. Below are the details
for OfficeAlly's certificate: |
| Organization: |
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OfficeAlly |
| Domain: |
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www.officeally.com |
| Country: |
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United States |
| Current Status: |
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Valid |
| Valid From: |
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02/18/2009 |
| Valid Until: |
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04/04/2011 |
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Transactions
ANSI (American National Standards Institute) is an organization that accredits
various standards-setting committees (i.e. ICD-9 and HCPCS). ANSI has accredited
a group called X12 that defines EDI standards for many American industries, including
health care insurance. Most of the electronic transaction standards mandated or
proposed under HIPAA are X12 standards.
Office Ally has
successfully tested with a third party vendor and is able to send and receive
the following HIPAA compliant transactions:
- Health Care Claim (837)
- Health Care Payment/Advice (835)
- Health Care Eligibility/Benefit Inquiry (270)
- Health Care Eligibility/Benefit Information (271)
- Health Care Status Request (276)
- Health Care Status Notification (277)
- Health Care Service Review Information (278)
- Benefit Enrollment and Maintenance (834)
- Payment Order/Remittance Advice (820)
Office Ally will continue to support non-standard format (NSF, Print Image, Text
files, etc.) after the October 16, 2003 deadline, as provided by the legislation.
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Disaster Recovery Plan
The Office Ally site is hosted at Net-fire INC. - the second largest server farm
in the country. Their state-of-the art backup and recovery procedures allow them
to boast a 99.992 % uptime. In addition to the Net-fire backup and recovery procedures,
Office Ally has its own backup and recovery procedures, tested the last weekend
of every month.
When a provider file is uploaded to the Office Ally website, a copy of the encrypted
file is immediately moved it to a backup server. Nightly, backup copies of the
database are made. We estimate that we could retrieve these copies and be operational
within 2 hours if needed. The data that would have been processed after the last
backup can be reprocessed and applied to the database within 30 minutes.
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Disclaimer and Contact
The above information does not constitute any warranties of any kind and is provided
for informational purposes only.
In the event that you need further information, please do not hesitate to contact
Office Ally's HIPAA Compliance Officer:
Gloria Chung
Manager
HIPAA Compliance Officer
(866) 575-4120
Fax: (360) 896-2151
Gloria.Chung@OfficeAlly.com
Office Ally
16703 SE McGillivray Blvd. Suite 200
Vancouver, WA 98683
www.officeally.com
support@OfficeAlly.com
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