The data table below shows the enforcement results by calendar year according to the type of closure for each category. This is the number of investigations that the Office of Civil Rights had resolved. There were:
Outcome of Complaint Investigations
Corrective Action Obtained
Resolved After Intake and Review
Outcome of Breach Compliance Review Investigations
A Request for Proposal (RFP) is one of the best ways to find out what each HIPAA security risk assessment vendor has to offer your organization, provided you structure it properly
From the August 2004 Issue of HIPAA Security Compliance Insider.
Like many organizations, your organization may not have the resources to conduct a HIPAA security risk assessment that compares your technical and nontechnical security measures to HIPAA’s requirements. That’s where an outside security assessment vendor can help. It can identify and explain your security weaknesses and the potential threats and vulnerabilities to your electronic protected health information (EPHI). Plus, a security assessment vendor can give you advice on what security measures you should implement to comply with HIPAA’s security regulations and stay in business.
But how do you know which security assessment vendor is the best one for your organization? One good way is to put together a request for proposal (RFP) that you send to prospective HIPAA security risk assessment vendors. Creating an RFP for prospective vendors will help you focus your security assessment project. And it will give you a chance to review and compare prospective vendors’ written responses to questions tailored to your organization. “Done well, an RFP is an indispensable tool for visualizing a project; and it provides a concrete roadmap for your relationship with the vendor you select,” says information technology attorney Jay Hollander.
We’ll tell you the steps you should take to start the process of choosing the right HIPAA security risk assessment vendor, including how to set up an RFP. And to help you set up your own, we’ll give you a Model Form of an RFP that you can adapt and distribute to potential vendors.
Follow Three Steps to Start Your HIPAA Security Risk Assessment Vendor Selection Process
According to Hollander, choosing a vendor to perform a HIPAA security risk assessment should start with three steps.
Assess needs/scope of project. First you must identify what areas your HIPAA security risk assessment should include. Do you need an assessment of your physical access controls and security policies? Should the vendor conduct a penetration test of your internal and external networks to see how easily they can be breached? “Each organization’s needs will be different,” says information security consultant Earl Crane. For example, smaller organizations that don’t transfer EPHI over extranet connections probably won’t need a security assessment of their extranet, he explains.
Insider Says: For a list of the various areas an organization’s security assessment might need to cover, click here. You can use this list to help you identify your own needs so you can communicate them to prospective vendors.
Narrow list of vendors. Next, you will need to get a list of prospective vendors. To do this, you can search for security assessment vendors on the Internet or ask colleagues for recommendations. Narrow your list by considering the vendors’ experience, general pricing approach, and the services they provide, says Hollander.
Focus on vendors that have the ability to assess both your technical and nontechnical security, recommends Crane. To get a complete picture of your security practices, you will need a technical assessment and a policy assessment, preferably by the same vendor, he explains. “Look for a vendor with a good understanding of HIPAA’s security regulations, and a good technical reputation,” he adds.
Prepare RFP. Once you’ve narrowed your list of prospective vendors down to four or five, it’s time to create an RFP. Your RFP, like ours, should include the following provisions:
Purpose and goals. Begin your RFP with a brief explanation of the reason you’re seeking a HIPAA security risk assessment vendor and your goals for the assessment—that is, to identify and repair security gaps and comply with the HIPAA security regulations.
Proposal contact and method of evaluation. Give prospective vendors the name and contact information of a knowledgeable person in your organization to whom they can go for more information. And tell them who should receive the proposals and any additional information your organization might need [Form, sec. 2(a)]. Also tell them the factors that will affect your decision to accept a proposal. Explain that your consideration of the proposals will be based on more than cost, says Crane. This way, they’ll understand that they may be rejected even if they have the lowest bid.
Schedule. Vendors will also need a schedule that outlines the RFP process from beginning to end, including the date when:
Responses to the RFP are due;
Vendor interviews will be held;
Supplemental information must be received;
A decision will be made; and
The project should start and finish.
Organization information. To understand the scope of the project and price it appropriately, prospective vendors will need a basic description of your organization and the information systems it currently uses. Be sure to describe all hardware and software, and let prospective vendors know how many active IP addresses your organization uses.
Scope of project. Based on the needs assessment you conducted before you narrowed down your vendor list, define the scope of the project in your RFP. Be precise, says Crane. Otherwise, your vendors might not bid on the same project, resulting in service and pricing differences that could be hard to identify and compare. And ask your vendors to break down their costs and the amount of time they require for each type of assessment you list in your RFP, Crane adds.
Confused? That’s okay! Call Aligned Risk Management for help: