Remember a few years ago we wrote about When it Comes to HIPAA Violations, Size Doesn’t Matter? Then it was a small specialty physician practice in Arizona that was hit with a penalty – now it’s a Denver pharmacy, Cornell Prescription Pharmacy. A well-known single-location pharmacy serving the greater Denver metropolitan area, they’re being pinged by OCR with a $125,000 penalty. They’ll also have to adopt a corrective action plan that corrects identified deficiencies in their HIPAA compliance program.
Much like that specialty practice in 2012, a penalty that would be peanuts to a multi-location, multi-state company hits this small business hard. They also suffer a blow to their reputation that’s harder to recover from when you’re that size. The Denver pharmacy specializes in compounded medications and service for hospice care agencies in the area and was outed to OCR by a local news outlet that learned about PHI of 1600 patients being disposed of (unshredded) in an unlocked, open container on the pharmacy premises. OCR investigated and learned that Cornell hadn’t implemented HIPAA Privacy Rule-required policies and procedures, plus had neglected to provide workforce training per the Privacy Rule requirements.
These are basics that can really bite when not met. We can only stress yet again that size doesn’t matter. The OCR doesn’t play favorites or only hit the big guys. They’re equal opportunity all the way! We work with so many small physician groups and vendors that seeing an OCR press release in our Inbox about a small organization just makes us cringe.
It’s okay to need help getting the basics in order. It beats relegating it to an ever-deferred “to-do” list. We’ll repeat ourselves here:
- Conduct a risk analysis
- Get BA contracts in order
Please avoid the headlines! You can even kick-start your Document to-do with these template-style Policy & Procedure manuals, which we developed for this very reason. If you’re ready to get started on your HIPAA Privacy Rule to-do list, give Apgar & Associates a call: 877-376-1981.