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Clean out Your Refrigerator and perform a Walkthrough

Did you know that November 15th is National Clean Out Your Refrigerator Day? Did you know that National Clean Out Your Refrigerator Day was created to encourage people to clean out their refrigerator in advance of the upcoming holidays?

It is often due to our hectic and busy lifestyles that the cleaning of the refrigerator gets neglected so hence the creation of National Clean Out Your Refrigerator Day. The timing of this special day dedicated to cleaning out the refrigerator falls just before the Thanksgiving holiday.

If a task such as cleaning out the refrigerator deserves a special day, what about a task such as performing a HIPAA walkthrough? With 2015 quickly approaching, wouldn’t it be nice to ensure your organization’s policies and procedures are up-to-date?

The following will offer tips for cleaning out your refrigerator and tips for performing your walkthrough by utilizing our online tool found on your Office Dashboard titled: HIPAA Virtual Walkthrough.

Empty each shelf

One of the most important steps involved with cleaning out the refrigerator is to empty each shelf. You might be surprised what you find on each shelf as you empty it. What may look like a science fair project may have really once upon a time been a meal.

During the HIPAA Virtual Walkthrough, one of the questions asked is, do you see documents containing PHI that might be visible to unauthorized individuals?

You might be surprised what you find by taking a moment to look over your desks and shelves. Take a moment to look over desks, shelves and other locations to ensure documents containing PHI are not visible to unauthorized individuals.  Documents containing PHI (i.e. appointment schedules, census lists, physician orders, EOBs, transcripts, super bills etc.) should not be visible to unauthorized individuals â€" including staff members and the public.

Completely wipe down the inside

Another important step in the cleaning out the refrigerator process is to completely wipe down the inside of the refrigerator. Wiping down the inside of a fridge is important for obvious reasons.

Think of the HIPAA Virtual Walkthrough as an opportunity to perform a “wipe down.”  During the walk through you may identify areas that need improvement. You might see things that are lacking, that may be unsecured, and that may lead to a breach.  Identifying those areas is only part of the process. The actual “wipe down” occurs once those areas have been successfully addressed.

Throw away all expired food

When it comes to cleaning out the fridge, this is self-explanatory. We can safely assume nobody wants expired food. When food is expired, for health and safety reasons, it is best to throw it out.

What about expired forms and information?

One of the sections of the HIPAA Virtual Walkthrough asks about your Notice of Privacy Practices (NPP). Is your NPP updated and posted in proper areas? If you are not using a NPP with the updated HIPAA Omnibus information, we recommend disposing of the expired NPP, and using a revised version. In the forms section on our website we have an NPP that is updated with the revised HIPAA Omnibus information effective September 2013, in addition to many other updated forms. If your State law requires other additional information on your NPP, that information should be added the federally required information.

Also, September 23, 2014 was the deadline to have your business associate agreements updated, signed and returned by your business associates. If your business associates have any sub-contractors that have access to your PHI, then they too must have signed business associate agreements in place with them. If you haven’t completed this critical step, you can access an updated business associate agreement online under our forms section.

Restock shelves and drawers with good food

Once again this is self-explanatory; however, we can safely assume food that isn’t expired, or doesn’t appear like a science fair project, is good food that is at the very least safe for consumption.

Performing the HIPAA Virtual Walkthrough annually is an opportunity to “restock” by ensuring your organization is up-to-date and in compliance with HIPAA Privacy and HIPAA Security standards. Restocking with current information that meets or exceeds HIPAA Privacy and Security standards is “good food” for your organization.

Did you know our training is updated whenever there are changes or updates to the law? Another way to “restock” is to ensure annual refresher training is completed by all employees.

Enjoy your nice clean, organized refrigerator

While cleaning out the refrigerator is generally a dreaded task, it is a task that is important none the less. Once the task is complete, it feels good to enjoy having a nice clean, organized refrigerator. The same can be said for HIPAA Privacy and Security.

Conducting your HIPAA Virtual Walkthrough helps identify HIPAA Privacy and Security areas that require attention. At the discretion of your compliance officer, correcting problems that were encountered during the walkthrough can prevent violations and ensure compliance with HIPAA standards.

Conclusion

National Clean Out Your Refrigerator Day was created to encourage people to clean out their refrigerator in advance of the upcoming holidays. With Thanksgiving just around the corner, it is a good time to have a nice clean, organized refrigerator. Performing a HIPAA Virtual Walkthrough is an opportunity to identify HIPAA Privacy and HIPAA Security opportunities for improvement. It is important for an organization to address these opportunities for improvement to ensure all information is up-to-date. If you haven’t performed yours yet this year, please take this time now to do so.

For more information about the HIPAA Virtual Walkthrough or if you have any additional questions, please do not hesitate to contact one of our professional consultants.

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