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HIPAA requirement for shredding and transportation of documents - Lisa


Posted: Apr 22, 2010

Can anyone tell me the specific HIPAA requirement for shredding and transportation of documents.  Can the shredding be outsourced or does it have to be in house and if it is transported to be shredded how does it need to be secured?  

HIPAA does not incorporate such specific guidelines. - sm

[ In Reply To ..]
HIPAA is really about outcomes in terms of securing PHI, and dictates very little in the way of the specific methods, technologies or procedures that an entity must follow in order to achieve those outcomes.

You can shred documents or have them shredded (there are now shredding companies that say they're "HIPAA-compliant" although, just like transcription companies, this claim can mean almost anything).

Sometimes these companies shred on site and you can supervise, obviously. If not, you can ask to accompany (or have an employee accompany) the load to the company's shredder site and observe it being shredded. Just observe the documents being loaded into the truck and then follow it in your own car. This would certainly satisfy the "reasonable precautions" required under HIPAA.

Remember that "incidental" exposure of PHI to an unauthorized party (as might happen during the handling required for shredding) is NOT considered to be a violation of HIPAA, so don't make yourself crazy with all kinds of imagined "HIPAA requirements".

Some info - Ima MT

[ In Reply To ..]
Myth or Fact:

In-house shredding programs prevent HIPAA related compliance issues from arising.

Fact. In-house shredding programs potentially create more HIPAA concerns than they resolve, because document destruction cannot be independently certified, and because proper security protocol is rarely practiced.

Respectfully disagree - sm

[ In Reply To ..]
Rarely does introducing a third party into any process make it inherently more secure or more reliable.

"Independent" verification does not imply "third-party" verification. A second employee, especially someone such as the entity's privacy officer, can be called upon to witness the destruction of the documents and no other "verification" is required.

As for using "proper security protocols", that is easily remedied by, well...using proper security protocols!

Don't be tricked into believing that you can't shred documents yourself. You most certainly can. Just do it right.

Hmmm.. - Horski

[ In Reply To ..]
The hospital I worked for was HIPAA compliant and very careful on all of these issues and we had someone pick it up. Actually, we had boxes that were locked and once you put in the box, even I couldn't get it back. It was considered destroyed already. They would come unlock the box and take the bag and replace with a new one. Very efficient.

"HIPAA compliant" has no particular meaning - when it comes to these matters.

[ In Reply To ..]
There is only one thing that "HIPAA compliant" means - i.e., that you have taken reasonable precautions to prevent the unauthorized disclosure of PHI.

The SPECIFIC MANNER in which you do this is NOT prescribed by HIPAA. You could burn the documents, soak them in a bleach solution, shred them or eat them, for that matter.

The government never intended to impose any "one size fits all" security solutions or procedures on anyone. They don't tell you whether you must use 128-bit encryption or 256. They don't tell you what your firewall settings must be. They don't tell you how many characters, or what kind, must be in your user passwords. They don't tell you how often you should review your server event or security logs. And they don't tell you how to dispose of paper records.

There are many, many covered entities located in places where there is no "secure" shredding service available. These facilities have absolutely NO problem whatsoever shredding their own documents and remaining perfectly "HIPAA compliant" while doing so!

I'm surprised incineration is not the only option. - hippa-hubba-bubba

[ In Reply To ..]
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