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CIPP-US Exam - Question 154


SCENARIO -

Please use the following to answer the next question:

Miraculous Healthcare is a large medical practice with multiple locations in California and Nevada. Miraculous normally treats patients in person, but has recently decided to start offering telehealth appointments, where patients can have virtual appointments with on-site doctors via a phone app.

For this new initiative, Miraculous is considering a product built by MedApps, a company that makes quality telehealth apps for healthcare practices and licenses them to be used with the practices’ branding. MedApps provides technical support for the app, which it hosts in the cloud. MedApps also offers an optional benchmarking service for providers who wish to compare their practice to others using the service.

Riya is the Privacy Officer at Miraculous, responsible for the practice's compliance with HIPAA and other applicable laws, and she works with the Miraculous procurement team to get vendor agreements in place. She occasionally assists procurement in vetting vendors and inquiring about their own compliance practices, as well as negotiating the terms of vendor agreements. Riya is currently reviewing the suitability of the MedApps app from a privacy perspective.

Riya has also been asked by the Miraculous Healthcare business operations team to review the MedApps’ optional benchmarking service. Of particular concern is the requirement that Miraculous Healthcare upload information about the appointments to a portal hosted by MedApps.

What can Riya do to most effectively minimize the privacy risks of using an app for telehealth appointments?

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Correct Answer: AD

The best way for Riya to effectively minimize the privacy risks of using an app for telehealth appointments is to engage in active oversight of MedApps. By doing so, she can ensure ongoing compliance with HIPAA and other privacy regulations, monitor any changes in MedApps' practices, and respond quickly to any potential breaches or issues. Requiring de-identification of all patient data (option A) is overly restrictive and not always practical, as some services may need identifiable information to function correctly. Prohibiting the use of subcontractors (option B) can limit the ability of MedApps to provide comprehensive support and services. Requiring a SOC2 report (option C) is useful but not sufficient on its own to manage dynamic privacy risks.

Discussion

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BhimeshOption: A
Apr 13, 2024

A. Require MedApps to de-identity all patient data.