What is the Key to Success for HIPAA Compliance?
The key to success for HIPAA compliance is developing an effective compliance program and then maintaining it through ongoing training, automation, monitoring, and sanctions when necessary – all supported by leadership buy-in.
The key to success for HIPAA compliance can vary according to the source of information. For example, sources focusing on HIPAA training suggest the key to success for HIPAA compliance is ongoing training, sources leaning towards technology solutions recommend automating as many workflows as possible, and – rather than focus on one key to success – sources providing compliance advice tend to advocate multiple compliance strategies.
None of the above keys to success for HIPAA compliance are wrong, and individually they can all contribute towards HIPAA compliance. However, ongoing HIPAA training is only an effective key to success if sufficient resources exist to support ongoing training if systems are in place to monitor post-training compliance, and if the organization’s sanctions policy is applied fairly and consistently. Otherwise, ongoing training can fail in its objective to be the basis for HIPAA compliance.
Similarly, automated workflows reduce the potential for human error – but only if the skillsets exist within the organization to correctly configure the automation software, monitor its effectiveness, and fine-tune configurations when necessary. Bearing this in mind, technology solutions are only viable contributors to HIPAA compliance if there is a use case for deploying them which reduces errors, time, and cost. Otherwise, they are an expensive luxury.
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Multiple compliance strategies can also contribute to HIPAA compliance provided the strategies work in unison to complement each other. One of the worst things that can happen when implementing multiple compliance strategies is that they are interpreted differently by department heads or by team supervisors so they are applied differently. For this reason, the key to success for HIPAA compliance is to approach HIPAA compliance holistically.
How to Approach HIPAA Compliance Holistically
To approach HIPAA compliance holistically, three elements are required – leadership buy-in, a knowledgeable compliance team, and effective communication.
Leadership Buy-In
Leadership buy-in is usually discussed in terms of taking an idea to the C-suite and obtaining approval to run with the idea. In this case the context is different because, in theory, leadership should have already bought into HIPAA compliance. Nonetheless, the objectives of obtaining C-suite approval to approach HIPAA compliance holistically are the same:
- Easier access to budget and resources
- Support for a cultural shift (or adjustment)
- Organizational sentiment from the top
- Program longevity
The proposal to approach HIPAA compliance holistically should come from multiple sources within the C-suite in order to overcome potential budgetary objections, demonstrate a top level commitment to compliance, present a joint view that a holistic approach is the approved approach, and ensure the continuation of the program when other events threaten to disrupt C-suite priorities.
Knowledgeable Compliance Team
Many organizations approach the task of designating the roles of HIPAA Privacy and Security Officers by assigning the roles to members of the workforce with limited expertise in compliance outside their own departments (i.e., IT, HR, and finance managers). However, it is important for the C-suite to ensure the right people are in the right positions to plan, organize, and execute an organization-wide holistic HIPAA compliance strategy.
This not only means having the positions of HIPAA Privacy and Security Officers filled by individuals with a wider knowledge of compliance, but also that the Officers are supported by a knowledgeable compliance team with the time and the skills to help plan, organize, and execute the strategy. In some cases, this may mean hiring new employees or retraining existing members of the workforce that have demonstrated an understanding of compliance.
What this doesn’t mean is filling the table with experts in compliance theory. What organizations need in their compliance teams are members of the workforce who understand the “ground-floor” challenges to compliance – such as dealing with upset patients and their families or security incidents. These members of the team will be better placed to explain to the HIPAA Officers what will work, what won’t work, and why, so that solutions to compliance challenges can be identified.
Effective Communication
With any workplace project, effective communication can be the difference between the project achieving its objectives or not. In the context of a holistic approach to HIPAA compliance being the key to success for HIPAA compliance, effective communication takes on an additional importance because, in order for an organization to be HIPAA compliant, every member of the workforce has to understand their responsibilities and obligations.
In this respect, it is essential to acknowledge there is no one-size-fits-all solution to effective communication. Whereas some workforces may be happy to adopt project management software to communicate ideas, raise concerns, and ask questions, you cannot force a communication channel on unengaged users and expect it to be effective. Therefore, identifying how to effectively communicate (for example) policy changes should be one of the first tasks for compliance teams.
It is also important for compliance teams to acknowledge that effective communication is not top-to-bottom driven. Measures or systems should be implemented to encourage two-way communication and feedback from ground-floor members of the workforce. Ideally, an anonymous communication channel should also exist to facilitate reports of HIPAA violations from members of the workforce who may be concerned about alienating colleagues or team members.
The Key to Success for HIPAA Compliance: Conclusion
While ongoing training, automated workflows, and multiple compliance strategies can contribute to HIPAA compliance, the real key to success for HIPAA compliance is a top-down commitment to compliance. This means providing the right people with sufficient resources to plan, organize, and execute a holistic approach to HIPAA compliance, and ensuring effective channels of communication exist to ensure every member of the workforce understands their responsibilities and obligations.
With the three elements in place to approach HIPAA compliance holistically, compliance teams can ensure sufficient resources exist to support ongoing training, determine whether a technology solution is viable, and monitor any conflicts between multiple compliance strategies – and whether these “keys to success” contribute to HIPAA compliance. However, without a holistic approach, you might never find the right key to success for HIPAA compliance.
