Compliant Printing/Mailing

At Webster, we understand that HIPAA compliance is an ongoing practice — subject to advances in technology, changing policies, new procedures, and updated HIPAA rules. It may seem counter-intuitive, but when set up and executed properly, adhering to HIPAA compliance strategies and systems can save time and resources in many ways.

With our daily workflow, we employ a set of security measures in place to ensure the safety and chain-of-custody of our print projects. Here’s a look at the process Webster uses when a HIPAA-flagged job moves through our plant.

Identifying HIPAA Jobs

At the beginning of the project, there are three ways that our team determines if a job requires HIPAA compliance:

  • If client-provided artwork contains private health information
  • If the data list contains private health information
  • If the combination of graphics, copy and data list may reveal private health information

Once we assign HIPAA status of an incoming job, we use several measures to ensure security from the start.

  • Files are transferred and stored on a secure server with restricted access
  • Our secure FTP site allows clients to transfer files in compliance with HIPAA regulations
  • All files are archived for 90 days
  • Data lists are scrubbed using NCOA, Move Update and CASS certification requirements

When it is determined that a job needs this level of compliance, we mark it in our production software as a HIPAA flag to ensure proper security procedures through every step of the workflow.

Print Production

When a HIPAA-flagged job enters the workflow, we have strict quality control and review processes in place to ensure compliance.

24/7, access-controlled and monitored printing process for HIPPA jobs

Cameras are located around the facility for controlled access

The only identifying information is the job specification ticket

When completing digital production on pre-printed variable pieces, the top sheet of every bin is covered during printing

Mail Processing

Our workflow is set up to move a HIPAA-flagged job through the production process and into the mail stream as soon as possible. Less time in the plant leaves less chance for any lapse in HIPAA compliance and security. This is where a strict workflow process so important. At Webster, we perform a critical structured turnaround on these jobs so there is no room for a potential violation.

When we receive a large job that exceeds a single-day capacity, the job is completed on the last full mail tray and then locked in a restricted-access storage room. Any pieces without variable data imprinting will remain in place. If we are working with digital jobs containing pre-printed variable information, the entire job will be stored in the restricted storage area.

The Importance of a HIPAA Workflow

The importance of HIPAA compliance cannot be overstated. In addition to possible financial penalties for non-compliance, it's our duty to protect the patient's most sensitive data. When we are entrusted with these jobs, we take the responsibility seriously. We know that creating and enforcing a step-by-step system allows us to deliver HIPAA-flagged jobs securely and with efficiency.

*To comply with the HIPAA Security Rule, all covered entities must: Ensure the confidentiality, integrity, and availability of all e-PHI. Detect and safeguard against anticipated threats to the security of the information. Protect against anticipated impermissible uses or disclosures that are not allowed by the rule.

What is HIPAA

HIPAA (Health Insurance Portability and Accountability Act) compliance pertains to protecting sensitive patient health information, commonly referred to as PHI (Protected Health Information). While HIPAA regulations primarily focus on electronic PHI (ePHI), such as that stored in electronic health records (EHR) or transmitted electronically, it also extends to PHI in other forms, including print media.

Here are some considerations for HIPAA compliance regarding print media:

  • Secure Printing Facilities: Ensure that print materials containing PHI are produced in secure facilities with restricted access to prevent unauthorized viewing or removal of printed materials.
  • Access Controls: Implement access controls to limit who can access printed materials containing PHI. This includes physical controls such as locked cabinets or rooms where printed materials are stored.
  • Document Disposal: Develop policies and procedures for the secure disposal of printed materials containing PHI. This might involve shredding or otherwise rendering documents unreadable before disposal.
  • Encryption: If printing PHI is necessary, consider encryption methods to protect the data during printing and ensure that only authorized personnel can decrypt and access the information.
  • Training and Awareness: Provide training to staff members who handle printed materials containing PHI on the importance of confidentiality and HIPAA compliance. This includes proper handling, storage, and disposal procedures.
  • Audit Trails: Maintain audit trails or logs to track access to printed materials containing PHI, including who accessed the information and when.
  • Business Associate Agreements (BAA): If you are outsourcing printing services to a third-party vendor, ensure that they sign a BAA acknowledging their responsibility to maintain HIPAA compliance when handling PHI.
  • Physical Security Measures: Implement physical security measures such as surveillance cameras, alarms, and restricted access areas to prevent unauthorized access to printed materials containing PHI.
  • Regular Audits and Reviews: Conduct regular audits and reviews of your print media practices to identify any potential HIPAA compliance gaps and address them promptly.

By incorporating these considerations into your print media processes, you can help ensure HIPAA compliance and protect the privacy and security of patient health information. It's also essential to stay updated on any changes to HIPAA regulations and adjust your practices accordingly.

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Webster Printing Co., Inc.

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