Information Access Management 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: Administrative Safeguards
TYPE: Standard
CITATION: 45 CFR 164.308(a)(4)(i)

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 (OCR). 45 CFR Part 164.308 (a)(4)(i) requires a covered entity to implement policies and procedures for authorizing access to ePHI that are consistent with the applicable HIPAA requirements.

UBIT limits access to ePHI to appropriately authorized UBIT workforce members. UBIT ensures implementation of policies and procedures for authorizing access to ePHI that are consistent with the applicable HIPAA requirements.

This policy applies to all UBIT workforce members.

Workforce members: Adhere to policies and procedures as written.

HIPAA Security and Privacy Officer: Ensures that the UBIT workforce has appropriate access to ePHI, in conjunction with the Human Resources Director. 

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

Human Resource Director or designee: Approves UBIT workforce members’ authorization and access to ePHI. In conjunction with the HIPAA Security and Privacy Officer, ensures appropriate access to ePHI.

Date Approved: 12/4/2017