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Health Data Breach Response Plan: A Managed Care Organization's

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Keep it to 3 pages - single spaced. 

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Health Data Breach Response Plan: A Managed Care Organization?s Comprehensive Plan


As the Chief Privacy Officer (CPO) of a competitive managed care organization, you have been


advised of a breach in the privacy, security and confidentiality of sensitive patient data that


occurred at the hands of an employee who was a willing participant in a large identify theft ring.


After a tip received from the FBI, a six (6) month investigation was conducted. The employee


sold hundreds of health records over the span of three (3) years for an undisclosed amount of


money. After immediate termination and prosecution, the next step is to develop a


comprehensive Health Data Breach Response Plan, a project assigned to you by the CEO.


Deliverables: The final product to submit is a comprehensive plan that includes the following:


Propose a data response plan that address the following:


o Step One: The organization?s response to the notification of a breach


o Step Two: Identify those responsible parties (by titles) to respond to the


notification of breach and explain each of their roles in the process


o Step Three: Procedure(s) to confirm the occurrence of a breach & identify the


involved scope/type of data involved


o Step Four: A three (3)-point system measure, to impact of the data breach & the


action(s) taken for each level of impact


o Step Five: Data breach response and corrective practices


o Step Six: Monitor/test effectiveness of response and corrective practices


o Step Seven: Notification (public and customer (specify whether all customers are


notified or just those impacted)


Proposed annual schedule of conducted risk analysis (frequency) to access the


organization?s susceptibility of data security risks and identify the identified person(s) to


conduct the scheduled risks analysis


Create a risk analysis data security checklist to identify human, technical, environmental,


and natural threats


o Required checklist categories: identified threat, contributing factors, example of


threat, the likeliness of occurrence and the potential impact to the organization


(negative impacts)


o Determine a system to determine/rate the likeliness of occurrence and the


potential impact to the managed care organization A list of specific resources in place to respond to a data breach


Identification and the incorporation Health Insurance Portability and Accountability Act


(HIPAA) security standards safeguards within the data response plan:


o Administrative Safeguards


o Physical Safeguards


o Technical Safeguards


Create an agenda of topics to present in an organization-wide employee training on the


topic ?What is My Role in the Prevention of an Organization?s Breach of Data?


TIPS on the assignment Keep it to 3 pages - single spaced.


3. Follow the steps in the assignment instructions. Only provide a few sentences per section.


Nothing verbose.


4. Pick two sections and drill down on them to add substance. Be thoughtful about which


sections to drill down on. Tell the reader why you are offering more substance in that particular


area. Consider your audience and the situation. Pick and choose what is important to say. You


may even say something like "more information will be needed to continue with this analysis


such as ..." to close out a section.


5. Provide "examples" or "reference materials" by inserting links in your document if that makes


sense to you.


6. Insert links in your document as source material instead of having a list of references.


7. Find examples on the internet and paraphrase them - use them as a guide - insert a hyperlink


so that you are referencing them properly and not taking credit for the work.


We are not reinventing the wheel. All of this information lives on the internet somewhere. Or, in


a guide of some sort. Have you taken advantage of resources that are offered by national


associations such as ACHE and others?


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