SBS has designed policies and procedures to clearly reflect how SBS complies with HIPAA:

• Administrative Safeguards –
  • SBS has adopted a written set of privacy procedures and has designated a privacy officer who is responsible for developing and implementing all required policies and procedures.
  • All procedures clearly identify employees who will have access to electronic protected health information (EPHI). Access to EPHI is restricted to only those employees who have a need for it to complete their job function.
  • SBS ensures that an appropriate ongoing training program regarding the handling of PHI is provided to all employees performing health plan administrative functions.
  • SBS as third party provides assurance to all covered entities through clauses in the contracts stating that SBS will meet the same data protection requirements that apply to the covered entity. SBS as third party doesn’t out-source any data handling functions to other vendors.
  • SBS has a well-defined contingency plan in place for responding to emergencies. SBS ensures backing up of data and have disaster recovery procedures in place. The plan has documented data priority and failure analysis, testing activities, and change control procedures.
  • SBS performs internal audits on all operations with the goal of identifying potential security violations.
  • SBS has documents with instructions for addressing and responding to security breaches that are identified either during the audit or the normal course of operations.

• Physical Safeguards – SBS controls the physical access to protect against inappropriate access to protected data
  • SBS controls the introduction and removal of hardware and software from the network.
  • SBS controls and monitors the access to equipment that contains health information.
  • Access to hardware and software is limited to properly authorized individuals.
  • At SBS, required access controls consist of facility security plans, maintenance records, and visitor sign-in and escorts.
  • SBS has all workstations in non-high traffic areas and monitor screens are not in direct view of the public.

• Technical Safeguards –
  • SBS ensures that all communications containing PHI if transmitted electronically over an open network is encrypted.
  • SBS ensures that the data within its systems has not been changed or erased in an unauthorized manner.
  • SBS maintains a written record of all configuration settings on the components of its network.