DEPARTMENT: Information Technology & Services PAGE: 1 of 3 APPROVED: July 21, 1999 EFFECTIVE DATE: October 1, 1999 POLICY DESCRIPTION: Corporate Appropriate Access REPLACES POLICY DATED: RETIRED: REFERENCE NUMBER: IS.AA.025 SCOPE: All Corporate-employed personnel or contractors engaged by the Corporate office who are users (“Corporate Users”) of the Clinical Patient Care System (“CPCS”). PURPOSE: To define, maintain and distribute Appropriate Access standards that include standards and procedures to be followed by all Corporate users of the Clinical Patient Care System (CPCS). POLICY: The company will provide to all Corporate users of CPCS an Appropriate Access Standards Manual. Each manual contains pertinent requirements for appropriate access to clinical and/or financial information. These requirements are developed to provide a Corporate user timely access to patient-specific information which is necessary to perform his/her job responsibilities and define the settings needed to support timely and appropriate access to patient information. Each Corporate user is ultimately responsible for adhering to the Corporate Appropriate Access standards. Corporate users must only access/view information that they have a legitimate “need to know” in order to perform their job responsibilities, regardless of the extent of access actually provided to the user. Users will access clinical and financial information in an honest, ethical and confidential manner. The access of patient information will be done in such a manner that, at a minimum, meets all applicable Federal and state laws, regulations, and accreditation standards. Compliance with the Corporate Appropriate Access standards will be measured by the monitoring specified in the standards, and through the oversight of the Corporate Security Committee. Noncompliance with these standards can result in an intentional or unintentional breach of patient confidentiality of medical records contained in CPCS. These standards and accompanying education will help to safeguard patient information and minimize exposure and/or liability for individual, facility and company users. These standards will be updated and modified to ensure compliance with changes in corporate policy and regulations, or to complement future system enhancements. PROCEDURE: The Corporate Appropriate Access Standards Manual will consist of four (4) content areas: 1. Policy statement Corporate Appropriate Access Policy, IS.AA.025. 2. Infrastructure for maintenance and support – establishes the committee oversight and DEPARTMENT: Information Technology & Services PAGE: 2 of 3 APPROVED: July 21, 1999 EFFECTIVE DATE: October 1, 1999 POLICY DESCRIPTION: Corporate Appropriate Access REPLACES POLICY DATED: RETIRED: REFERENCE NUMBER: IS.AA.025 departmental staff position for maintenance of standards, and requirement for signing of Information Security Agreement. These standards address: Corporate Security Committee Local Security Coordinator Designation Information Security Agreement 3. Global Access Standards – Subject areas such as Release of Information and Enforcement and Discipline are addressed in these standards. The requirements in these standards complement and are consistent with facility Appropriate Access requirements, referenced below. The Corporate Global Access standards include: External Entity Access Sealed Patient Record Access Confidential Patient Record Access Release of Information and Re-Disclosure MIS Access PCI Menu Access Conformance and Monitoring Enforcement and Discipline 4. Department-Specific Standards – Each pertinent department within IT&S and Operations is described in detail as related to CPCS access needs. Access is defined within each module for each different position description within the department. Global issues are addressed in all standards, such as access to emulation and security level settings. IT&S Departmental Standards Operations Departmental Standards REFERENCES: Corporate Appropriate Access Standards CPCS Appropriate Access, IS.AA.001 Multi-Facility Security Committee Policy, IS.AA.002 Facility Security Committee Policy, IS.AA.003 Release of and Access to Demographic and Clinical Patient Information Policy, IS.AA.004 Re-Disclosure of Patient Health Information Policy, IS.AA.005 Confidential Patient Setting in CPCS, IS.AA.006 DEPARTMENT: Information Technology & Services PAGE: 3 of 3 APPROVED: July 21, 1999 EFFECTIVE DATE: October 1, 1999 POLICY DESCRIPTION: Corporate Appropriate Access REPLACES POLICY DATED: RETIRED: REFERENCE NUMBER: IS.AA.025 Sealed Patient Setting in CPCS, IS.AA.007 PCI Menu Access, IS.AA.008 Restrict by Location, IS.AA.009 Physicians and Physicians Office Staff, IS.AA.010 External Entity Access, IS.AA.011 Employee Health Records, IS.AA.012 Information Security Policy, IS.AA.013 Conformance & Monitoring Reports Policy, IS.AA.014 Enforcement and Discipline Policy, IS.AA.015