Methods of Individual Notification 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: Notification in the Case of Breach of Unsecured Protected Health Information
TYPE: Implementation Specification for Notification to Individuals
CITATION: 45 CFR 164.404 (d) Implementation Specification: Methods of Individual Notification

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 164.404 requires a covered entity, following the discovery of a breach of unsecured PHI, to notify the appropriate individuals.

UBIT provides notification of a breach of unsecured ePHI to affected individuals in writing. 

If there is insufficient or out-of-date contact information that precludes written notification, a substitute form of notice reasonably calculated to reach the individual shall be provided.

In any case deemed by UBIT to require urgency because of possible imminent misuse of unsecured protected health information, UBIT may provide information to individuals by telephone or other means, as appropriate, in addition to written and or a substitute form of notice.

This policy applies to all UBIT workforce members.

Workforce members: Adhere to policies and procedures as written.

HIPAA Security and Privacy Officer: Ensures that required notification to individuals is provided in writing, or as deemed necessary, through a substitute format.

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

Date Approved: 12/6/2017