For radiology providers who are covered entities, the new HIPAA rules will,
at a minimum, require revisions to their
notice of privacy practices, authorization
forms, business associate agreements,
HIPAA privacy and security policies and
procedures, and an overall assessment of
their HIPAA compliance.
The HIPAA Megarule underscores
that covered entities must reassess and
strengthen their HIPAA compliance,
or face potential severe monetary con-
sequences for their failure to do so.
Though September 23, 2013, may seem
like it is far away, the HIPAA Megarule
is extensive and complex. In order to
achieve new HIPAA compliance, radi-
ology providers should get started now
by doing a gap analysis to see what they
are missing from a HIPAA Privacy and
Security Rule perspective, what must
be revised, and otherwise conduct an
overall assessment of the impact of the
HIPAA Megarule on their practices.
Adrienne Dresevic, Esq. is a founding shareholder of
The Health Law Partners, PC. She graduated Magna
Cum Laude from Wayne State University Law School.
Ms. Dresevic practices in all areas of healthcare law
and devotes a substantial portion of her practice to
providing clients with counsel and analysis regarding
compliance and Stark and fraud and abuse. She is a
member of the American Health Lawyers Association,
American Bar Association (ABA), State Bar of Michigan,
and State Bar of New York. Ms. Dresevic is the Chair of
the Publications Committee of the ABA Health Law
Section. She also is the Chair of the ABA Fraud and
Abuse Toolkit and has served as the Chair of the ABA
eSource publication. Ms. Dresevic has written
extensively and co-authors a column in AHRA’s monthly
newsletter Link. Ms. Dresevic can be contacted at
firstname.lastname@example.org or by visiting www.thehlp.com.
Clinton Mikel, Esq., is a partner at The Health Law
Partners, PC. He is a graduate of Cornell University
and the University of Michigan Law School. Mr. Mikel
practices in all areas of healthcare law and devotes
a substantial portion of his practice to providing
clients with counsel and analysis regarding HIPAA,
telemedicine, compliance, Stark, and Anti-kickback.
He is a member of the American Bar Association’s
Health Law Section, the American Health Lawyers
Association, and the State Bars of California and
Michigan. Mr. Mikel is the Vice Chair of the ABA’s
eHealth, Privacy & Security interest group, and is a
Vice Chair of the ABA’s Health Law Section Publications
Committee. Mr. Mikel has written extensively, including,
co-authoring a column in AHRA’s monthly newsletter,
Link. Mr. Mikel can be contacted at email@example.com
or by visiting www.thehlp.com.