Scope
Defines covered records, departments, and communication channels (phone, secure portal, email, text, paper) so staff know which interactions require special handling.
Adopting formal procedures reduces privacy risk and supports enforceability by documenting intent, consent, and retention practices; electronic communications and signatures are recognized under federal law (ESIGN, 15 U.S.C. ch. 96) while HIPAA sets privacy and breach-notification obligations that the policy helps meet.
Healthcare organizations of all sizes use these procedures to control PHI sent by phone, email, portal, or signed forms.
A clear assignment of roles in the procedure helps ensure consistent application and faster breach response.
Oversees policy adoption, performs periodic audits, and coordinates breach reporting to OCR; ensures written procedures align with HIPAA and organizational risk tolerances.
Maintains retention schedules, approves access roles, and validates that communication templates and form fields capture required patient consent and authorization language.
Defines covered records, departments, and communication channels (phone, secure portal, email, text, paper) so staff know which interactions require special handling.
Clear PHI and PHI-adjacent definitions, plus terms such as 'authorized user', 'consent', 'secure channel', and 'de-identified' to reduce ambiguity during implementation.
Specifies signer and recipient verification methods (knowledge-based questions, SMS OTP, account login) and thresholds for different disclosure risk levels.
Sets encryption requirements for in transit and at rest, acceptable messaging vendors, and file-format controls to prevent accidental disclosure.
Describes breach detection, internal escalation, patient notification triggers, OCR reporting obligations, and post-incident remediation steps.
Schedules staff education, documents audit frequency, and defines metrics for compliance monitoring and corrective actions.
| Field | Configuration |
|---|---|
| Authentication | SMS OTP required | KBA optional for high-risk |
| Encryption | TLS 1.2/1.3 in transit | AES-256 at rest |
| Audit Trail | Capture IP, timestamp, user ID, and actions |
| Retention | Apply HIPAA 6-year baseline; override for state law |
Ensure chosen platforms support required security, integrations, and legal assurances for health data handling.
Verify platform-specific BAAs, API capabilities, and access controls before enabling electronic signatures or automated messaging for PHI.
Annually or upon material change to law or practice
Initial training within 90 days of hire; annual refreshers
Report suspected breaches internally immediately upon discovery
Notify OCR and affected individuals as required; large breaches often reported within 60 days (45 CFR §164.408)
Quarterly technical checks and annual program audits
Leadership review and formal sign-off of the procedures.
Enable encryption, authentication, and audit logging.
Test with a limited group and refine templates.
Organization-wide adoption with training completed.
The practice standardized electronic consent forms and secure portal messages to patients
A small operator digitized signature processes for tenant communications
| signNow | DocuSign | Adobe Sign | PandaDoc | HelloSign | |
|---|---|---|---|---|---|
| Starting Price | $8/user/mo | $15/user/mo | $14/user/mo | $19/user/mo | $15/user/mo |
| Free Trial | 7-day free trial | Varies by vendor | Varies by vendor | Varies by vendor | Varies by vendor |
| Bulk Send | Yes (Business Premium) | Yes | Yes | Yes | No |
| Audit Trail | Yes | Yes | Yes | Yes | Yes |
| HIPAA Compliant | Yes (BAA available) | Yes | Yes | No | No |