HIPAA Interim Privacy Officers

Interim Privacy Officers from Strategic Management

The HIPAA Privacy Rule requires a covered entity to designate a Privacy Officer responsible for developing and implementing its privacy policies and procedures, as well as to serve as a contact person/office responsible for receiving complaints and providing individuals with information on the entity’s privacy practices. In the event a Privacy Officer is needed, the process of finding qualified candidates to fill the role, as well as initial onboarding, can be very time consuming. Often, this process takes many months.

To help organizations fill the need of Privacy Officers, Strategic Management provides highly trained and experienced Interim Privacy Officers who are able to quickly assess and address organizational HIPAA needs, deficiencies, and gaps. These certified HIPAA experts possess the in-depth knowledge of the HIPAA privacy laws and regulations, as well as complaint management processes.

Interim Privacy Officers are an Effective Solution for HIPAA Compliance

HIPAA privacy laws and regulations play an important role in protecting both the organization and the employees who participate. In most cases, an in-office Privacy Officer oversees the privacy compliance of an organization. Through maintaining and overseeing the integrity, security, and confidentiality of protected health information, all individuals associated with an organization benefit.

However, finding a dedicated Privacy Officer is a unique challenge in and of itself. If an organization’s compliance program needs additional support or lacks the personnel to perform essential HIPAA privacy functions, they have traditionally been forced to go through an expensive and time-consuming hiring process. Fortunately, there are additional options to maintain HIPAA compliance without needing to find a full-time dedicated employee.

Interim Privacy Officer Responsibilities and Functions

Just like permanent privacy officers, Interim Privacy Officers help organizations meet HIPAA privacy rule requirements and remain compliant. Here are some of the ways this is accomplished:

  • Implementing and developing privacy policies, procedures, and privacy related documents such as Notice of Privacy Practices, authorization forms, and others.
  • Developing and conducting privacy training.
  • Providing ongoing auditing and monitoring of the privacy program.
  • Performing privacy risk assessments.
  • Reporting to executives, officers, and managers about privacy program status.
  • Assisting leaders in planning, designing, and evaluating privacy and security-related projects to ensure compliance.
  • Coordinating with Human Resources to determine appropriate sanctions for individuals not complying with privacy policies.
  • Documenting and reporting any violations of privacy policies.
  • Updating privacy programs to comply with the latest laws, regulations, and accreditation requirements.

The Advantages of Using Interim Privacy Officers

Choosing an interim privacy officer delivers many benefits to the organizations.  Advantages include:

  • Independent Objective: Since Interim Privacy Officers come from outside of the organization, they offer a fresh and objective view of an organization’s current privacy program. They have no investment in prior decisions or preconceived notions about the program. This allows them to deliver insights that can significantly benefit an organization. Additionally, Interim Privacy Officers provide senior management and boards with an independent assessment of the status of the privacy program. If changes need to be made, Interim Privacy Officers will have no problem reporting this.
  • Resourceful: Interim Privacy Officers can help identify qualified candidates for the permanent position. Their familiarity with HIPAA privacy rule requirements and privacy best practices and allows interim officers to evaluate candidates with a level of knowledge that other company representatives cannot provide.
  • Diverse Background: Usually, Interim Privacy Officers have worked in a wide variety of settings and have experience with different challenges and environments. This gives them valuable insights into what works and what does not work in a variety of settings.
  • Continuity: One of the most important roles Interim Privacy Officers play is giving incoming permanent privacy officers a compliance “roadmap” to follow. This means incoming Privacy Officers will be able to immediately begin implementing organization privacy program, reducing the amount of time lost while determining how to act. This allows for continuity of the organization’s privacy program.

Does Your Organization Need One?

Outsourcing Privacy Officer responsibilities and functions can benefit many organizations, especially those without the resources to hire a Privacy Officer full-time. Ask the following questions to determine whether your organization can outsource a portion or all of the responsibilities of a Privacy Officer.

  • Is there a vacancy due to temporary leave or turnover? If there is a vacancy, your organization should consider outsourcing the position until a replacement is found. The Interim Privacy Officer can actually help find a qualified permanent replacement. They can also work onsite and offsite. Remember, under HIPAA covered entities which includes health care providers, health care clearing houses, and health plans are required to designate a Privacy Officer.
  • What are the privacy officer’s responsibilities? Do they wear many hats? If your program has a Compliance Officer who also serves as the Privacy Officer, but needs additional support, a portion of the Compliance Officer responsibilities such as training, investigations, breach analysis, among other responsibilities can be outsourced.

If you would like to learn more about how an Interim Privacy Officer can benefit your organization, contact Strategic Management Privacy Specialists today.

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