Page 10 - 2021 Risk Reduction Series - Communication Part Two
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SVMIC Risk Reduction Series: Communication


                 place certain safeguards. Depending on the content of the

                 text message, who the text message is being sent to, or the
                 mechanisms put in place to ensure the integrity of the ePHI,

                 texting can be in compliance with HIPAA in certain limited
                 circumstances.



                 Messages can be sent by text, provided that the content of

                 the message does not include personal identifiers and that
                 the message complies with the minimum necessary standard.

                 The technical safeguards of the HIPAA Security Rule require
                 access controls, audit controls, integrity controls, methods for

                 ID authentication, and transmission security mechanisms when
                 PHI is being transmitted via text. Among these requirements are

                 the following:

                     •  Access to PHI must be limited to authorized users who

                        require the information to do their jobs.

                     •  A system must be implemented to monitor the activity

                        of authorized users when accessing PHI, and those
                        with authorization to access PHI must authenticate

                        their identities with a unique, centrally issued username
                        and personal identification number (PIN). Policies and

                        procedures must be introduced to prevent PHI from being
                        inappropriately altered or destroyed.


                     •  Data transmitted beyond an organization’s internal

                        firewall should be encrypted to make it inaccessible if it is
                        intercepted in transit.



                 SMS and IM text messages (the types commonly used by
                 most everyone today) often fail on all these counts. Senders

                 of SMS and IM text messages have no control over the final
                 destination of their messages. They could be sent to the wrong




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