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:

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

Step Two: Identify those responsible parties (by titles) to respond to the notification of breach and explain each of their roles in the process

Step Three: Procedure(s) to confirm the occurrence of a breach & identify the involved scope/type of data involved

Step Four: A three (3)-point system measure, to impact of the data breach & the action(s) taken for each level of impact

Step Five: Data breach response and corrective practices

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

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

Required checklist categories: identified threat, contributing factors, example of threat, the likeliness of occurrence and the potential impact to the organization (negative impacts)

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:

Administrative Safeguards

Physical Safeguards

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”