Accountability Policy (UBIT HIPAA)

Category: HIPAA Security
Responsible Office: UBIT HIPAA Compliance
Responsible Executive: Vice President and Chief Information Officer (VPCIO)
Approved By (Name/Title): J. Brice Bible, VPCIO

CATEGORY: Physical Safeguards
TYPE: Addressable Implementation Specification for Device and Media Controls Standard
CITATION:  45 CFR 164.310(d)(2)(iii)

The University at Buffalo Information Technology (UBIT) operates as a covered entity as defined by the U.S. Department of Health and Human Services Office of Civil Rights.  HIPAA Regulation Text 45 CFR Part 164.310(d) requires a covered entity to implement policies and procedures that govern the receipt and removal of hardware and electronic media that contain electronic protected health information into and out of a facility, and the movement of these items within the facility.

UBIT maintains a complete, accurate, and up-to-date inventory of hardware and electronic media on which ePHI is stored. This inventory logs and tracks the movement of UBIT’s hardware and electronic media on which ePHI is stored and any person(s) responsible therefore. UBIT’s HIPAA Security and Privacy Officer takes reasonable steps to ensure that all such movement is promptly and accurately logged and tracked.

This policy applies to all UBIT workforce members.

Workforce members: Adhere to policies and procedures as written.

HIPAA Security and Privacy Officer: Ensures a record is maintained of the movements of hardware and electronic media containing ePHI.

Compliance Officer: Participates in ensuring security of ePHI is effective and enforced, in conjunction with the HIPAA Security and Privacy Officer.

Date Approved: 12/6/2017