Enterprise MVPs 2021 Privacy Rule

Our Enterprise MVPs ™ (minimally viable processes) describe processes that heretofore have never existed in the Privacy Rule, for the three most insidious and disruptive requirements of the new Rule. Our MVPs ™, complete with Swimlane process diagrams and supporting documentation, answer many of the questions the  Rule left unanswered, including gnarly and complex questions of law, which we analyzed as part of MVP development. Each Enterprise MVP ™ has a corresponding Mini-MVP ™ for policies, processes, training,  and other information required by front office staff at the point of care ("POC"), which is where most of the liability lies. This product is only available as part of our Subscription(s).

Under the Rule’s Right to Access and Inspect (§164.524) the patient now has the following expansive new rights (i.e., they are the most insidious and disruptive, but there are others):
  1. The right to inspect at the time of appointment (“TOA”) and the point of care (“POC”) enables patients to enter your facility "to view, create videos, take photographs and use other resources."
  2. The right to enter your facility to inspect at a “convenient time and place” (“CP&T”) (e.g., OCR uses the examples of a medical records facility) do perform the same actions described above.
  3. The reduced time to provide patients access to their PHI (i.e., like the old Rule) except with the amount of time cut in half from thirty (30) to fifteen (15), with the extension remaining intact.

Our Enterprise MVPs ™ ship with complete with the supporting documentation, that includes, but is not limited to, the following topics: (1) Standards of Law Identified; (2) Standards of law as Applied; (3) use cases to which these standards pertain; (4) expansive descriptive information for each lane/box in a Swimlane Diagram ("SLD"); (5) policies, processes and legal recommendations made pursuant to the three most insidious requirements; (6) how to avoid instead of creating liability under the new Rule; and (7) comprehensive overview training.

Our solution for these rights represents a small part of our value proposition. Our MVPs provide all requirements for compliance with an elegant and legally defensible solution. For example, our solution includes requirements for POC training, processes, and what staff must do to mitigate, instead of creating liability; this documentation is comprehensive. Rights to access and inspect, almost always occur at the POC and are where patient encounters generally happen. It is also where the lion’s share of the liability lies.

Our MVPs jettison your organization's understanding of the challenges posed by the Rule and dramatically compresses your decision-making. They rapidly bring key stakeholders up to speed on the processes and legal issues inherent in the Rule. They also enable you to spend your resources focusing on the investment required to actuate the MVPs. All implementation decisions flow from MVPs; establishing the requirements for your initiative.


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