Fluency HIPAA and HITECH Overview
				
					Fluency enables entities and their associates to leverage the secure Fluency environment
                    to process, maintain, and store protected information. Fluency is able to support
                    the HIPAA and HITECH regulations, as well as the ability to sign HIPAA Business
                    Associate Agreements (BAAs) with customers. Fluency works hard to maintain our ongoing
                    investment in enterprise security, compliancy and control for our customers.
				
				What is HIPAA, HITECH Act and the Final HIPAA Omnibus rule?
				
					HIPAA stands for the Health Insurance Portability and Accountability Act of 1996.
                    It is a federal mandate that requires specific security and privacy protections
                    for Protected Health Information (PHI). More information around HIPAA can be found
                    here: http://www.hhs.gov/ocr/privacy/index.html
				
				
					HIPAA was expanded by the Health Information Technology for Economic and Clinical
                    Health (HITECH) Act, which was signed into law in 2009. HITECH was implemented to
                    promote the adoption and meaningful use of health information technology in the
                    U.S.
				
				
					In 2013, the final HIPAA Omnibus rule set further statutory requirements, which
                    greatly enhanced a patient’s privacy rights and protections, including holding all
                    custodians of Protected Health Information (PHI) — including HIPAA Business Associates
                    (BA) — subject to the same security and privacy rules as Covered Entities under
                    HIPAA.
				
				How does Fluency facilitate HIPAA compliance for its customers?
				
					The Fluency environment meets the obligations required by HIPAA, HITECH, and the
                    final HIPAA Omnibus ruling.
				
				
					Fluency has a standard BAA we present to customers for signature. A signed BAA should
                    be in place prior to storing any Protected Health Information (PHI) in the Fluency
                    environment.
				
				
					Customers are also responsible for enforcing policies in their organizations to
                    meet HIPAA compliance.
				
				Is Fluency HIPAA-Certified?
				
				
					There are no official government or industry certifications for HIPAA compliance.
                    In order to support HIPAA compliance, Fluency has reviewed the HIPAA regulations
                    and updated its product, policies and procedures to support customers around their
                    need to be HIPAA compliant.
				
				How does Fluency support HIPAA compliance within its product and platform?
				
					In addition to being able to sign HIPAA Business Associate Agreements (BAAs), Fluency
                    has the following features in its product as well as organizational policies:
				
				
					- Data encryption in transit and at rest
- Restricted physical access to servers
- Strict logical system access controls
- Configurable administrative controls available to the customer to:
- Grant explicit authorization to customer files to read, download, edit, lock and
                        password protect files
- Reporting and audit trail of account activities on both users and content
- Training of employees on security policies and controls
- Employee access to customer data files are highly restricted
- Greater than 99.5% uptime SLA
What types of customer and administrator controls does Fluency have that are relevant
                to HIPAA requirements?
				
					- Controls to provide reasonable assurance that only authorized individuals from the
                        user entity are granted the ability to access, modify, and delete information from
                        the application.
- Controls to provide reasonable assurance that the user entity’s method for accessing
                        the application is configured with proper logical security protocols.
- Controls to provide reasonable assurance that the confidentiality of the user entity’s
                        sensitive information is not compromised by its users.
- Controls to provide reasonable assurance for defining and granting access to users
                        permitted by the user entity.