Category: Mobile Devices

OIG Fiscal Year 2015 Work Plan

On October 31, 2014, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) released the Work Plan for Fiscal Year 2015 (“Work Plan”). The Work Plan confirms OIG will continue to concentrate a great deal of their enforcement efforts on the security and vulnerabilities of protected health information (“PHI”) contained in electronic health records (“EHRs”). The continued focus on data security contained in EHRs aligns with the goals of the OIG Strategic Plan 2014-2018, where OIG identified EHRs as one of its key focus areas until at least 2018.

Given the increased frequency and publication of health information breaches, it is no surprise the OIG for the first time indicated it plans to examine hospitals’ contingency plan policies and procedures to determine if adequate safeguards are in place in the event systems containing PHI are damaged. OIG also indicated it will continue to examine the Centers for Medicare & Medicaid Services’ (“CMS”) oversight of hospitals’ security controls over networked medical devices, such as dialysis machines, radiology systems and medication dispensing systems. OIG will also continue to conduct audits of eligible hospitals and professionals who received Medicare and Medicaid Meaningful Use Incentive payments to determine whether such payments were proper.

It is worth noting the Work Plan did not include assessing the security and vulnerabilities of portable devices containing PHI as a priority. This may be an indication  OIG has completed its review of the issue.

Click here to read OIG’s Work Plan.

If you have any questions or would like additional information about these topics, please contact:

New FTC Guidance Addresses Social Media Advertising; Could FDA Be Next?

On March 12, the Federal Trade Commission (“FTC”) published new guidance detailing how advertising disclosures should be made online.  Disclosures are necessary to qualify or limit advertising claims that would otherwise be deceptive, unfair or give misleading impressions.

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FTC Issues Mobile Privacy and Security Publications

On February 1, 2013, the Federal Trade Commission (FTC) issued two publications recommending ways that key players in the mobile marketplace, such as operating system providers, application developers, advertising networks and analytics companies, can promote mobile privacy and security.

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ECRI Institute Publishes Top 10 Health Technology Hazards for 2013

ECRI Institute has released its list of the Top 10 Health Technology Hazards for 2013.  The annual report is based on the prevalence and severity of incidents reported by health care facilities and information found in the Institute’s medical device problem reporting databases.

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Establishing an Effective Records Management and Data Retention Program: Health Care Industry Considerations

Attached is a link to a webinar that I recently conducted with Teramedica on Establishing an Effective Records Management and Data Retention Program: Health Care Industry Considerations.

This one-hour webinar helps health care organizations gain tactical insight into the essential legal and business requirements of establishing an effective records management and data retention program. Patient data storage and data access is becoming one of the most costly and challenging areas of health care delivery.Continue Reading →

mHealth Task Force report recommends greater FCC involvement in health care.

On September 24, the mHealth Task Force, released its recommendations to the Federal Communications Commission (FCC) which recommends greater FCC involvement in mobile health and greater coordination with the FDA, ONC, HHS and other federal agencies…. Continue Reading →

Opinions about Mobile Device Privacy and Security Due to ONC by March 30, 2012

The public comment period regarding securing health information while using mobile devices ends on March 30, 2012. Information regarding ONC’s Mobile Device Roundtable discussion and a link to provide comments can be found here.

Should you have any questions, please contact Alisa Kuehn at 317.977.1475 or