There is some common ground in the corrective action plans (CAP) that OCR has imposed on healthcare organizations it has investigated for HIPAA privacy and security deficiencies.
Editor's note: The following is adapted from the HCPro book The HIPAA Omnibus Rule: A Compliance Guide for Covered Entities and Business Associates, by Kate Borten, CISSP, CISM, president of The Marblehead Group in Marblehead, Mass. To learn more about the book, go to www.hcmarketplace.com.