Security Risk Analysis Compliance Form

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SECURITY RISK ANALYSIS COMPLIANCE FORM
This form is intended to be used by a Provider [an Eligible Professional (EP) or Eligible Hospital (EH)] as documentation in support
of the Meaningful Use (MU) Measure for “Protect Patient Health Information”. Protecting “Patient Health Information (PHI)”
includes conducting and/or reviewing a “risk analysis” of the Provider’s or organization’s activities, policies and procedures for
handling and maintaining the security of PHI. All responses included in this form are subject to verification during an on-site post-
payment audit and any responses found to be inaccurate, unsupportable or false may result in a failure of the MU measure and
recoupment of the incentive payment. (This form may be completed by an authorized staff person on behalf of the Provider.)
1. Provider Information
Provider’s Name & Professional Title:__________________________________________________ NPI:___________________
If EP, Name of Practice or Organization:
_________________________________________________________________________________ NPI:___________________
2. My Organization
b) Size (number of staff including Professional, Technical, Clerical
a) Type
& other support, FT, PT & volunteers)
___ FQHC/RHC
___ 5 or less
___ Group Practice
___ 6 - 10
___ Individual or Shared Office
___ 11 – 25
___ Outpatient Clinic
___ 26 – 50
___ Hospital
___ 51 – 100
___ 100+
3. Written Policies and Procedures
a) My organization has at least one formal written policy on the handling and security of PHI. ____Yes ___No
b) We have the following written policies and procedures (check all that apply):
___ HIPAA Compliance
___ IT Security
___ Maintaining and Protecting PHI
___ Business Associate’s Agreement (BAA)
___ Other (describe):____________________________________________________________________
c) We have required staff training on security and protecting PHI on at least an annual basis. ___Yes ___No
If “Yes”, then (check all that apply):
(i)
____ Training is conducted on a group/seminar basis
(ii)
____ Individual, self-study basis
(iii)
____ Other (explain)
_______________________________________________________________________________
4. CEHRT
a) Date my organization’s CEHRT was installed*:_____________________ (mm/yyyy)
b) Date of the most recent upgrade of my organization’s CEHRT: ___________________ (mm/yyyy)
*If you have not changed your CEHRT product/vendor since your very first EHR Incentive Program attestation, this will be the original implementation
date. If you changed product/vendor since your very first attestation, indicate the implementation date of the current CEHRT.
5. Risk Analysis
(Defined as: Phase I - auditing, reviewing and/or evaluating the organization’s written and informal practices, policies and procedures
regarding the handling, maintenance and protection of PHI, and Phase II – making a critical evaluation of the results of Phase I, and taking
any appropriate actions to mitigate or address any deficiencies noted in Phase-I including making appropriate changes or improvements in
the organization’s existing formal/written practices, policies and procedures.)
a)
Risk Analyses for my organization, whether Phase-I and/or Phase-II, are conducted by (check all that apply):
_____Staff within the organization*
_______ Contractors
_____ Other (describe):__________________________________________________________
b)
When was the last Phase-I Risk Analysis conducted for your organization? __________________ (mm/yyyy)
c)
What period did the Phase-I Risk Analysis cover?
Review Period Begin Date:______________________ Review Period End Date:______________________
d)
When was the last Phase-II Risk Analysis conducted for your organization? __________________ (mm/yyyy)
e)
_____ No formal risk analysis (such as a formal written report) was conducted during the Program Year.
If you checked this item, please state reason
(example of an acceptable reason may include “small office [<5] and risk analysis matters
:_________________________________________________
addressed during mandatory all-staff meetings with notes/minutes taken)
_____________________________________________________________________________________________________
*This may include staff within the Provider’s immediate office. If the organization has different divisions, sections, offices, etc., or dedicated staff for
internal audits or compliance reviews, and staff from such areas of the organization perform the risk analyses, they should be viewed as “staff within
the organization”.
This form is being submitted in support of the attestation of the above named Provider for Program Year ______________.
If applicable, initial here: _______ “I am authorized to complete and sign this form on the Provider’s behalf”.
______________________________________________________________________
Printed Name & Title:
________________________________________________________
Signature:
Date:_____________________
Rev 06/30/16

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