security policies and procedures (HIPAA)

Covered entities must implement "reasonable and appropriate policies and procedures to comply with the standards, implementation specifications and other requirements" of the Security Rule. Policies and procedures will implement -- directly or by alternative means -- the administrative, physical and technical safeguard components of the Rule.

What level of detail is required in these policies and procedures? Following its principle of "scalability," the Rule requires only that they be "reasonably designed, taking into account the size and type of activities of the covered entity that relate to electronic protected health information." (Final Rule, p.165)

Covered entities may change their security policies at "any time, provided the changes are documented and are implemented in accordance with the [Security Rule]." Such documentation, like the policies and procedures they document, must be reviewed and updated periodically. How often is that? As frequently as would be "reasonable and appropriate," of course.

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