6.6. ERMUSR 05-16-2006 - Laserfiche WebLink

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Elk River Municipal Utilities Health Plan HIPAA Security Policy Elk River Munic~al Utilities ("Plan Sponsor") sponsors one or more health plans ("The Plan(s)" or "Plan(s)") for eligible employees. The Plan(s) is(are) a "Covered Entity" as defined by the Health Insurance Portability and Accountability Act of 1996, Pub. L. 104-191 (HIPAA). Pursuant to the Security Standards contained in HIPAA (45 CFR 160 and 164), the Plan Sponsor adopts this Security Policy ("Policy") for the protection of Electronic Protected Health information (ePHI). The Plan(s) is not (are not) administered by a third party acting as a "Business Associate" of The Plan(s) as defined by 45 CFR § 160.103. 1. Effective Date The Plan's Security Policy is effective Apri120, 2006. The Policy will remain in force until changed or rescinded by The Plan Sponsor's designated Security Official or Board Action. 2. Security Management Process Risk Analysis and Risk Management [§164.308(a)(1)(ii)(A) and §164.308(a)(1)(ii)(B)] The covered entity has conducted a thorough assessment of potential security risks related to any Plan ePHI and made the following risk and vulnerability determinations: 1. The Plan(s) occasionally maintains or transmits limited ePHI, the Plan(s) maintains or transmits no ePHI that is critical to the health or life of Plan members. 2. ePHI maintained by The Plan(s) may be important to Plan operations, but is rarely mission critical. 3. Appropriate security measures implemented by The Plan(s) to protect the confidentiality and integrity of this information are described in this policy. Employee Sanctions [§164.308(a)(1)(ii)(C)] The Plan(s) and Plan Sponsor will apply appropriate employee sanctions, consistent with existing plan sponsor employee discipline and sanction policies, to any employee of The Plan Sponsor who violates The Plan's Security Policy. Sanctions can include termination of employment when appropriate. 3. Security Official The Plan(s) will officially designate a Security Official and maintain written record of the designation. The current Security Official designation is the Finance Director. Responsibilities of The Plan(s) Security Official include: