HIPAA Privacy and Security Initial Training For Employees - PowerPoint Presentation

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HIPAA Privacy and Security Initial Training For EmployeesCompliance is Everyone’s Job

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INTERNAL USE ONLY

For UA Health Care Components, Business Associates & Health PlansSlide2

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Topics to Cover

General HIPAA Privacy and Security Overview

HIPAA Privacy

HIPAA Breach Notification Rules and Procedures

HIPAA SecuritySlide3

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What is HIPAA?

The Health Insurance Portability and Accountability Act (HIPAA) is federal legislation which addresses issues ranging from health insurance coverage to national standard identifiers for healthcare providers.

The portions that are important for our purposes are those that deal with protecting the privacy (confidentiality) and security (safeguarding) of health data, which HIPAA calls Protected Health Information or PHI.Slide4

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Applicability of HIPAA to UA

HIPAA Applies to:

University Medical Center

Brewer-Porch Children's Center

The Speech & Hearing Center

Autism Spectrum Disorders Clinic

Departments that have signed Business Associate Agreements

Group Health Insurance/Flexible Spending Plan/

Wellbama

Program

UA Administrative Departments supporting the above entities (like Legal Office, Auditing, Financial Affairs, Risk Management, OIT, UA Privacy/Security Officer, etc.)

Research involving PHI from a HIPAA-covered entity

Does not apply to Psychology Clinic, Student Health Center/Pharmacy, ODS records, Counseling Center, WRC, Athletic Dept health recordsSlide5

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What is Protected Health Information (PHI)

Any information, transmitted or maintained in any medium, including demographic information

;

Created/received by covered entity or business associate;

Relates to/describes past, present or future physical or mental health or condition; or past, present or future payment for provision of healthcare; and

Can be used to identify the patientSlide6

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Types of Data Protected by HIPAA

Written documentation and all paper recordsSpoken and verbal information including voice mail messages

Electronic databases and any electronic information, including research information, containing PHI stored on a computer, smart phone, memory card, USB drive, or other electronic device

Photographic images

Audio and Video recordingsSlide7

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To De-Identify Patient Information You Must Remove All 18 Identifiers:

Names

Geographic subdivisions smaller than state (address, city, county, zip)

All elements of DATES (except year) including DOB, admission, discharge, death, ages over 89, dates indicative of age

Telephone, fax, SSN#s, VIN, license plate #s

Med record #, account #, health plan beneficiary #

Certificate/license #s

Email address, IP address, URLs

Biometric identifiers, including finger & voice prints

Device identifiers and serial numbers

Full face photographic and comparable images

Any other unique identifying #, characteristic, or code

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Department of Justice-Imposed Criminal Penalties for Employee

Wrongfully Accessing or Disclosing PHI: Fines up to $50,000 and up to 1 Year in Prison

Obtaining PHI Under False Pretenses: Fines up to $100,000 and up to 5 Years in Prison

Wrongfully Using PHI for a Commercial Activity: Fines up to $250,000 and up to 10 Years in Prison

HIPAA criminal and civil fines and penalties can be enforced against INDIVIDUALS as well as covered entities and Business Associates who obtain or disclose PHI without authorization Slide9

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Federal-Imposed Civil Penalties

Violation Category

Each Violation

All Identical Violations per Calendar Year

Did

Not Know

$100 - $50,000

$1,500,000

Reasonable

Cause

$1000 - $50,000

$1,500,000

Willful

Neglect-

Corrected

$10,000 - $50,000

$1,500,000

Willful

Neglect-Not

Corrected

$50,000

$1,500,000 Slide10

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Federal-Imposed Civil Penalties

HHS is now

required

to investigate and impose civil penalties where violations are due to

willful neglect

Federal government has six (6) years from occurrence of violation to initiate civil penalty action

State attorneys general can pursue civil cases against INDIVIDUALS who violate the HIPAA privacy and security regulations

Civil penalties now apply to Business AssociatesSlide11

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Breach and Sanction Information

Breach Notifications: September 2009 –

January 2017:

1820

reports involving a breach of over 500

individuals

Total individuals affected

171,283,823

Top 3 types

of

breaches

Theft (747 or 41%)

Unauthorized

access/disclosure (438 or 24%)

Hacking/IT Incident (260 or 14%)

Top

3 locations

for large breaches

Paper

records (405 or 22%)

Laptops (293 or 16%)

Network Server (256 or 14%)Slide12

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Breach and Sanction Information

Stolen Laptop

Stanford University

Lucile Packard Children’s Hospital (2013

)

An

unencrypted laptop

containing medical information on pediatric

patients was

stolen from a secured access room

Laptop was older model with damaged screen; it was not being used in normal day-to-day operations

Laptop

contained

patient

names, ages, medical records, surgical procedures, and

names

and telephone numbers of various physicians

This HIPPA breach affected over 13,000 patients

If

the laptop had been encrypted, the PHI would not have been exposed and this would not have been a breachSlide13

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Breach and Sanction Information

Theft of a Portable Electronic Device

Georgetown

University

Hospital

(2010)

Notified

2,416 patients that their

PHI (names, DOB, clinical information) had

been compromised

Employee

inappropriately emailed

PHI to an offsite research office (not HIPAA-covered entity) in violation of the review preparatory to research protocol

Research office stored the

ePHI

on

external hard drive that was later stolen

Employee given verbal warning & counseling

Hospital stopped transmitting PHI to research office & undertook review of all research affiliations involving PHI of its patients to confirm that appropriate documentation and procedures were in placeSlide14

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Breach and Sanction InformationEmployee Misconduct: Terminations

University of Miami (2012)

Two university employees were

terminated

for

inappropriately accessing

64,846 patients’ “face sheets” (patients’ names, DOB, insurance policy numbers, partial & full Social Security numbers, and clinical information)

University of California at Los Angeles Health System (UCLAHS) (2011)

Paid HHS $865,500 to resolve complaints of

intentional unauthorized access

to/use/disclosure of PHI

Two celebrity patients alleged employees reviewed their medical records without authorization

Employees had repeatedly been caught and

fired

for looking at records of celebrities (Brittney Spears,

Farrah

Fawcett)

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Breach and Sanction InformationEmployee Misconduct: Probation & Jail Time

2008: 25-year-old LPN working at Northeast Arkansas Clinic inappropriately accessed a patient’s PHI & shared it with her husband, who immediately called the patient & threatened to use PHI against him in upcoming legal proceeding

LPN fired. Indicted for wrongful disclosure of PHI for personal gain and malicious harm

LPN faced maximum of 10 years in prison, fine of no more than $250,000 or both, and term of supervised release of not more than 3 years

LPN sentenced to 2 years probation & 100 hours community service

Arkansas State Board of Nursing: suspend or revoke license

2010: Licensed cardiothoracic surgeon working at UCLA School of Medicine as a researcher looked at employee and patient medical records he was not authorized to view

Pled guilty to four misdemeanor charges. Prosecutor asked for 90 days in jail and fine of $500, because he had received formal training on HIPAA violations, unlawfully accessed records after hours & was terminated.

Sentenced to four months in federal prison and $2,000 fine

First HIPAA violation resulting in incarceration Slide16

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UA HIPAA Sanctions

Employees, students, and volunteers who do not follow HIPAA rules are subject to disciplinary action

UA sanctions depend on severity of violation, intent, pattern/practice of improper activity, etc., and might include:

Dismissal from academic program

Termination of employment

Suspension without pay

Denial of an annual raise or reduction in pay

Civil and/or criminal penalties including incarcerationSlide17

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Authorization as Permitted Use and Disclosure of PHI

A covered entity can generally use and disclose PHI for any purpose if it gets the person’s signed HIPAA-valid authorization

Only designated, HIPAA-trained personnel are permitted to approve disclosure of PHI per the person’s HIPAA-valid authorization

For any questions concerning authorization, please contact your Privacy Officer

For a complete list of permitted uses and disclosures of PHI without the patient’s authorization, see your entity’s Notice of Health Information PracticesSlide18

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TPO as Permitted Use and Disclosure of PHI

PHI may be used and disclosed to facilitate TPO, which means:For TreatmentFor Payment

For certain healthcare Operations, such as quality improvement, credentialing, compliance, and

patient/employee

safety activitiesSlide19

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Can Family/Friends Know?

Yes, but only PHI directly relevant to that person’s involvement with the patient’s healthcare or payment related to patient’s healthcare

And, only if the provider reasonably infers that the patient does not objectSlide20

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What About Deceased Patients?

Family/friends involved in care can receive information related to care or payments, unless inconsistent with patient’s prior expressed preferencesRecords of person deceased for more than 50 years is no longer protected under HIPAASlide21

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What About Immunization Records to Schools?

Okay to disclose proof of immunization to School where state or other law requires School to have information prior to admitting studentNeed oral agreement (phone/email) documented in patient’s medical recordSlide22

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Use or Disclosure of PHI for Fundraising

Permissible to give to business associate or related foundationDemographic informationDates health care provided

for fundraising, but only if included in Notice of Health Information Practices & patient is given chance to opt outSlide23

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Minimum Necessary Standard

When HIPAA permits use or disclosure of PHI, a covered entity must use or disclose only the

minimum necessary

PHI required to accomplish the purpose of the use or disclosure.

The only exceptions to the minimum necessary standard are those times when a covered entity is disclosing PHI for the following reasons:

Treatment

Purposes for which an authorization is signed

Disclosures required by law

Sharing information to the patient about himself/herselfSlide24

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What HIPAA Did Not Change:

Family and friends can still pick up prescriptions for sick people

Physicians and Nurses do not have to whisper

State laws still govern the disclosure of minor’s health information to parents (a minor is under the age of 19 in Alabama)Slide25

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Question

Jenny, a pediatric nurse, needs to report lab results to the mother of a 3 year old child who is sitting in the waiting room. She sticks her head in the waiting room door and says, “Good news. The lab results are normal.” Is this a privacy breach?

Yes

NoSlide26

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Correct Answer

a: Yes, unless no one else was in the waiting room. The nurse should have asked the mother to step out into the hallway or taken other steps to minimize the risk that someone would overhear the conversation.Slide27

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Other Privacy Safeguards

Avoid conversations involving PHI in public or common areas such as hallways or elevatorsKeep documents containing PHI in locked cabinets or locked rooms when not in use

During work hours, place written materials in secure areas that are not in view or easily accessed by unauthorized persons

Do not leave materials containing PHI on desks or counters, in conference rooms, on fax machines/printers, or in public areas

Do not remove PHI in any form from the designated work site unless authorized to do so by management

Never take unauthorized photographs in patient care areas including audio and videoSlide28

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Notice of Health Information Practices

Explains how the covered entity will use/disclose patient’s PHIExplains a patient’s rights and where to file a complaintIs offered to a patient at the time of the first visit (and patient should sign & date acknowledgement of receiving at time of first visit)

Is posted on facility’s web

page

and in patient reception areaSlide29

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Patient Rights Under HIPAA

The Notice of Health Information Practices outlines the patient’s following rights to:Restrict disclosure of PHI to health plan if patient pays out of pocket in full for the

healthcare

item/service

Look at and obtain a copy of

record/PHI or

ePHI

Amend incorrect or misleading information in record

Receive an accounting

of disclosures of PHI

Be notified of a breach of PHI

File a complaintSlide30

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Question

Charlie works at a medical center and is responsible for entering billing data into the computer system. He looks at his mother-in-law’s medical records, because he is concerned that she has not been fully honest with her family about some recent health problems. Since he has been HIPAA trained, is this a breach of privacy?

Yes

NoSlide31

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Correct Answer

a: Yes. Although Charlie has been HIPAA trained, his access is based on the minimum necessary requirement to complete his job. He does not need to access health records to enter billing data. Unless his mother-in-law has given permission, in writing on a HIPAA-valid authorization, for him to access her records, this action was a violation of Privacy Policies.Slide32

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Business Associate (BA) Agreements

Are required before a covered entity can contract with a third party individual or vendor (subcontractor) to perform activities or functions which may involve the use or disclosure of the covered entity’s PHI

Law now requires BA to comply with certain Privacy and Security rules & subjects BA to HIPAA criminal and civil penalties.

BA also subject to breach of contract claims

BA Agreement must be approved in accordance with appropriate UA policies and procedures

Individual employees are NOT authorized to sign contracts on behalf of UA.Slide33

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HIPAA Put New Requirements on Research

If you work for a HIPAA-covered Health Care Provider, do not release PHI for research unless:

The patient has signed a valid HIPAA authorization, or

The Institutional Review Board (IRB) at UA has approved a waiver of authorization; or

The IRB agrees that an exception applies

Information regarding HIPAA and Research is available through UA’s Office for Research Compliance.Slide34

34Breach Notification

HIPAA requires that we notify affected individuals and federal officials when a breach or potential breach of privacy has occurred

The following slides discuss:The types of breaches requiring patient notification and those that are exempt

Time in which the notification must occur

Responsibility of employee to report any incident

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35What is a Breach?

Breach is defined as the unauthorized acquisition, access, use, or disclosure of unsecured PHI which compromises the security or privacy of the information.

Impermissible use or disclosure is presumed to be a breach unless the facility or business associate proves that there is a low probability that PHI has been compromised.

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36Risk Assessment Required

To assess the probability that PHI has been compromised, we are required to consider:The nature and extent of PHI and likelihood of re-identification (credit card/SSN, etc.)

Unauthorized person who used PHI or to whom disclosure was madeWhether PHI was actually acquired or viewed

The extent to which the risk of PHI has been mitigated (recipient destroyed it)

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37Exceptions When Breach Notification Not Required

Unintentional acquisition, access, or use of PHI by an employee or individual acting under the authority of a covered entity or business associate if made in good faith or within course and scope of employment

Inadvertent disclosure of PHI from one person authorized to access PHI at a covered entity or business associate to another person authorized to access PHI at the covered entity or business associateUnauthorized disclosures in which an unauthorized person to whom PHI is disclosed would not reasonably have been able to retain the information

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38Home Free – No Notification Required

“Home free” methods under which breaches

involving the misuse, loss, or inappropriate disclosure of paper or electronic data would indicate no harm

done, and therefore, no patient notification:

PHI is encrypted in both storage (servers, desktops, laptops, thumb drives, tablets, etc.) and in transit (https: or SSL encryption while accessing electronically).

PHI

has been properly disposed (paper is shredded with an appropriate shredder, pulped or incinerated; electronic storage devices such as hard drives, thumb drives, CD/DVD, etc., are properly erased with a

DoD

-approved data erasure process).

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Encryption

Security Rules require Covered Entity/Business Associate to consider implementing encryption as

a method for safeguarding Electronic Protected Health Information (PHI)

If you encrypt, then patient notification is not required in event of breachSlide40

40What Constitutes a Breach?

A breach could result from many activities. Some examples are

Accessing more than the minimum necessaryFailing to log off when leaving a workstationUnauthorized access to PHI

Sharing confidential information, including passwords

Having patient-related conversations in public settings

Improper disposal of confidential materials in any form

Copying or removing PHI from the appropriate area

Why?

Curiosity…about a co-worker or friend

Laziness…so shared sign-on to information systems

Compassion…the desire to help someone

Greed or malicious intent…for personal gain

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41Question

Bill, a billing employee, receives and opens an email containing PHI which a nurse, Nancy, mistakenly sent to Bill. Bill notices that he is not the intended recipient, alerts Nancy to the misdirected email, and deletes it.

Was this a breach of PHI

that requires notification to the patient

?

Yes

No

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42Correct Answer

b:

No. Bill unintentionally accessed PHI that he was not authorized to access. However, he opened the email within the scope of his job for the covered entity. He did not further use or disclose the PHI.

This was not a breach of PHI as long as Bill did not further use or disclose the information accessed in a manner not permitted by the Privacy Rule.

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43Question

Rob, a research assistant, wanted to get ahead on some statistical work, so he copied the information from 240 research participants to his thumb drive. The information included PHI, and the thumb drive was not encrypted. On his way home to continue his work, he stopped by the store to get some snacks. When he returned to his car, he found it had been broken into. Missing were his GPS, dozens of CDs, and his book bag containing the thumb drive.

Does this event constitute a breach

requiring patient notification

?

Yes

No

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44Correct Answer

a:

Yes. Unsecured PHI was stolen because the thumb drive was unencrypted.

Actually, Rob violated many UA policies:

Removed confidential information from the unit without approval

Used his personal portable computing device for UA business without senior management approval

Copied confidential information to a portable computing device without senior management approval

Used a portable computing device that was not encrypted

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45Breach Notification Regulations

If it is determined that a breach of PHI occurred, then the

covered entity must notify the affected individual (or next of kin) without unreasonable delay

,

but not later than 60 calendar

days from discovering the breach.

Time runs when

incident

first known or reasonably should have been known (true for covered entity and business associate), NOT when it is determined that a breach occurred.

Breach is treated as discovered when workforce member or other agent has knowledge of incident

That means an employee or volunteer must IMMEDIATELY report!

Delay permissible in certain circumstances where law enforcement has requested a

delay

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46Responsibility to Report Promptly

When receiving a privacy complaint, learning of a suspected breach in privacy or security, or noticing something is “just not right,” we must work together

If you notice, hear, see, or witness any activity that you think might be a breach of privacy or security, please let your organization’s privacy and/or security officer know immediately

It is much better to investigate and discover no breach than to wait and later discover that something DID happen

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Security Standards – General Rules

HIPAA security standards ensure the confidentiality

,

integrity

, and

availability

of PHI created, received, maintained, or transmitted electronically (PHI –Protected Health Information) by and with all facilities

Protect against any reasonably anticipated threats or hazards to the security or integrity or such information

Protect against any reasonably anticipated uses or disclosures of such information that are not permittedSlide48

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Rules for Access

Access to computer systems and information is based on your work duties and responsibilities

Access privileges are limited to only the minimum necessary information you need to do your work

Access to an information system does not automatically mean that you are authorized to view or use all the data in that system

Different levels of access for personnel to PHI is intentional

If job duties change, clearance levels for access to PHI is re-evaluated

Access is eliminated if employee is terminated

Accessing PHI for which you are not cleared or for which there is no job-related purpose will subject you to sanctionsSlide49

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Question

Once employees have completed HIPAA training, their access to PHI is

Unlimited

Based on work duties and responsibilities

Limited to the minimum necessary information to complete required work

Both B and CSlide50

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Correct Answer

d: Access to PHI is based on need-to-know which is determined by the employee’s duties and responsibilities. The employee should only access the minimum PHI necessary to complete the required task. Slide51

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Rules for Protecting Information

Do not allow unauthorized persons into restricted areas where access to PHI could occur

Arrange computer screens so they are not visible to unauthorized persons and/or patients; use security screens in areas accessible to public

Log in with password, log off prior to leaving work area, and do not leave computer unattended

Close files not in use/turn over paperwork containing PHI

Do not duplicate, transmit, or store PHI without appropriate authorization

Storage of PHI on unencrypted removable devices (Disk/CD/DVD/Thumb Drives) is prohibited without prior authorizationSlide52

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Encryption of PHI

Encryption is generally necessary to protect information outside of the Electronic Medical Records (EMR) systemUse of other mobile media for accessing and transporting PHI such as smart phones,

iPads

, Netbooks, thumb drives, CDs, DVDs, etc., presents a very high risk of exposure and requires appropriate authorization

Use of any personally owned laptops, desktops or other mobile devices (non-UA equipment) for accessing PHI requires appropriate authorization

Help UA avoid costly patient notification process by following University policy that requires encryptionSlide53

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Password Management

Do not allow coworkers to use your computer without first logging off your user account

Do not share passwords or reuse expired passwords

Do not use passwords that can be easily guessed (dictionary words, pets name, birthday, etc.)

Should

not be written down, but if writing down the password is required, must be stored in a secured location

Should be changed if you suspect someone else knows it

Disable passwords or delete accounts when employees

leave

Passwords:

Should be

minimum 8

characters long

Include 3 of 4 data types (upper/lower case, numeric, special characters)

Should be changed periodically

Good password scheme is critical for complex passwords – R0llt!de (don’t use this, just an example)Slide54

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Protection from Malicious Software

Malicious software can be thought of as any virus, worm, malware, adware, etc. As a result of an unauthorized infiltration, PHI and other data can be damaged or destroyed

Notify your supervisor, system support representative, and/or security officer

immediately

if you believe your computer has been compromised or infected with a virus—do not continue using computer until resolved

Managed anti virus and other security software is installed on all University computers and should not be disabled

Any personal devices used for access to PHI must have appropriate anti virus software

Do not open e-mail or attachments from an unknown, suspicious, or untrustworthy source or if the subject line is questionable or unexpected—DELETE THEM IMMEDIATELY Slide55

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Ransomware

Ransomware is malicious software that denies access to data, usually by encrypting the data with a private encryption key that is only provided once the ransom is paid  Presence of ransomware (or any malware) on a covered entity’s or business associate’s computer systems is a security incident

Whether it results in an impermissible disclosure of PHI and/or a breach depends on the facts and circumstances of the attack

When

ePHI

is encrypted due to a ransomware attack, a breach has occurred because the

ePHI

was acquired

Once the ransomware is detected, we must initiate our security incident and response and reporting procedures

If computer with encrypted data is powered on and the operating system loaded, the data is decrypted and breach notification may need to occur

Notification of a breach of unencrypted or decrypted data must occur unless there is a  “low probability the PHI has been compromised”

Maintaining frequent backups and ensuring ability to recover data from backups may show low probability (if no exfiltration of PHI)Slide56

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Beware of Suspicious Emails

Be very cautious of suspicious emails that request information such as email ID and password, or other personal information claiming that you need to verify an account, or you are out of disk space, or some other issue with your account. If they claim to come from the University check the following:

From Address: Make sure the from address has ua.edu after the @ sign

URL Link: If you can see the URL in the message, make sure it has ua.edu before the first slash (/)

Hover trick: If you can’t see the URL, you can “hover” your mouse pointer over the link WITHOUT CLICKING and a box with the URL will appear. Check for ua.eduSlide57

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Rules for Disposal of Computer Equipment

Only authorized employees should dispose of PHI in accordance with retention policies

Documents containing PHI or other sensitive information must be shredded when no longer needed. Shred immediately or place in securely locked boxes or rooms to await shredding.

All questions concerning media reallocation and disposal should be directed to your HIPAA Security Officer; OIT systems representatives or your departmental IT support teams are responsible for sanitization and destruction methods

Media, such as CDs, disks, or thumb drives, containing PHI/sensitive information must be cleaned or sanitized before reallocating or destroying

“Sanitize” means to eliminate confidential or sensitive information from computer/electronic media by either overwriting the data or magnetically erasing data from the media

If media are to be destroyed, then once they are sanitized, place them in specially marked secure containers for destruction

NOTES: Deleting a file does not actually remove the data from the media. Formatting does not constitute sanitizing the mediaSlide58

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Use of Technology

Use of other mobile media for accessing and transporting PHI such as smart phones, iPads, Netbooks, thumb drives, CDs, DVDs, etc., presents a very high risk of exposure and requires appropriate authorization

Email, internet use, fax and telephones are to be used for UA business purposes (see UA policies)

Fax of PHI should only be done when the recipient can be reliably identified; Verify fax number and recipient before transmitting

No PHI is permitted to leave facility in any format without prior approval

Where technically feasible, email should be avoided when communicating unencrypted sensitive PHI - follow your organization’s email policy for PHI

No PHI is permitted on any social networking sites (Twitter, Facebook, MySpace, etc.)

without appropriate authorization

No PHI is permitted on any chat platforms (AOL, MSN, cell phones) – if required, use protected email or text methods

If a situation requires use of

email

or text, appropriate encryption techniques must be used. Slide59

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Question

Your office computer is being replaced. You should

Delete all files that might contain sensitive information

Have the computer sent to surplus for secure storage

Contact your HIPAA Security Officer to initiate steps to sanitize the computerSlide60

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Correct Answer

c: Contact your HIPAA Security Officer. Deleting files from a hard drive will not permanently remove the files from the computer. Computers should not be taken to surplus until they have been sanitized. Not all used computers go to surplus. Some are reassigned for further use.Slide61

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Facility Access Controls

Help to monitor the controls we have for Facility Access

Sign-in Visitors and Vendors (as required)

Insure that locks, card access, or any other physical access controls are working as expected

Report any problems or possible problems to your security officerSlide62

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Reporting Security Incidents

Notify your Security Officer of any unusual or suspicious incident

Security incidents include the following:

Theft of or damage to equipment

Unauthorized use of a password

Unauthorized use of a system

Violations of standards or policy

Computer hacking attempts

Malicious software

Security Weaknesses

Breaches to patient, employee, or student privacySlide63

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UA Contacts

Know Your Security and Privacy Officer:

University-wide Privacy Officer: Jan

Chaisson

University-wide Security Officer: Ashley Ewing

University Medical Center Privacy Officer is Jan Chaisson

University Medical Center Security Officer is Amy Sherwood

Brewer Porch Privacy/Security Officer is Warren Williams

Speech and Hearing Privacy/Security Officer

is

JoAnne Payne

Autism Spectrum Disorders Clinic Privacy/Security Officer is Sarah Ryan

UA Group Health Plan/FSA Privacy Officer is Emily

Marbutt

UA Group Health Plan/FSA Security Officer is Greg Gaddis

WellBAMA

Program Privacy/Security Officer is Heather Clayton

Working on Womanhood Program (WOW) Privacy/Security Officer is Jill Beck

Center for Advanced Public Safety (CAPS) Privacy/Security Officer is Vaughn Poe

Institutional Review Board Compliance Officer is Tanta Myles

College of Education Alabama Medicaid Agency Project Privacy/Security Officer: Rick Houser