Honest Broker: Difference between revisions

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Reviewed Date: ''' ''' <br /><br />
Reviewed Date: ''' ''' <br /><br />


'''<big>Honest Broker</big>''' <br /><br />
'''<big>Honest Broker Policy</big>''' <br /><br />
==Basis for Policy==
==Basis for Policy==
==Policy==
==Policy==
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A person or entity, other than a member of the workforce of a covered entity, who performs functions on behalf of a covered entity per 45 CFR 160 is a business associate.
A person or entity, other than a member of the workforce of a covered entity, who performs functions on behalf of a covered entity per 45 CFR 160 is a business associate.
===De-identification===
===De-identification===
De-identification refers to removal of all 18 of the HIPAA identifiers or any other identifiers which would allow the reasonable possibility for investigators or others to identify patients directly or indirectly to prevent re-identification of patients.
De-identification refers to removal of all eighteen (18) of the HIPAA identifiers or any other identifiers which would allow the reasonable possibility for investigators or others to identify patients directly or indirectly to prevent re-identification of patients.
===Information Custodian===
===Information Custodian===
All application systems must have an information custodian '''''(IM17, Access Control to Information Technology Resources)''''' who performs the following functions:  '''''(IM29 - Information Custodian Roles and Responsibilities)'''''
All application systems must have an information custodian '''''(IM17, Access Control to Information Technology Resources)''''' who performs the following functions:  '''''(IM29 - Information Custodian Roles and Responsibilities)'''''
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*The individual or the organization or team must submit an [http://www.unmc.edu/hipaa/_documents/application-for-honest-broker-certification.pdf Application for Honest Broker Certification Form] to become part of the UNMC Honest Broker System.
*The individual or the organization or team must submit an [http://www.unmc.edu/hipaa/_documents/application-for-honest-broker-certification.pdf Application for Honest Broker Certification Form] to become part of the UNMC Honest Broker System.
:*The Honest Broker Certification applications are available at http://www.unmc.edu/hipaa/forms/index.html.
:*The Honest Broker Certification applications are available at http://www.unmc.edu/hipaa/forms/index.html.
"*Applications should be submitted to the Privacy Officer for the ACE.  
:*Applications should be submitted to the Privacy Officer for the ACE.  
*Attestation of Agreement: All Honest Brokers must sign a written agreement that they will abide by all relevant ACE policies including continuing adherence to the ACE Honest Broker certification criteria section of this policy.  
*Attestation of Agreement: All Honest Brokers must sign a written agreement that they will abide by all relevant ACE policies including continuing adherence to the ACE Honest Broker certification criteria section of this policy.  
*Certification, Approval, and Maintenance
*Certification, Approval, and Maintenance
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*[http://www.unmc.edu/hipaa/_documents/application-for-honest-broker-certification.pdf Application for Honest Broker Certification Form]
*[http://www.unmc.edu/hipaa/_documents/application-for-honest-broker-certification.pdf Application for Honest Broker Certification Form]
*[http://www.unmc.edu/hipaa/_documents/attestation-of-honest-brokers-responsibilites.pdf Attestation of Honest Brokers Responsibilities Form]
*[http://www.unmc.edu/hipaa/_documents/attestation-of-honest-brokers-responsibilites.pdf Attestation of Honest Brokers Responsibilities Form]
*[https://unmcredcap.unmc.edu/redcap/surveys/?s=9TsTE2UGsM UNMC/Nebraska Medicine EHR Service Request Form]
*[http://newintranet.nebraskamed.com/AnalyticsRequest/Login.aspx?ReturnUrl=%2fanalyticsrequest%2f Analytics Request Form]


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