The Centers for Medicare and Medicaid Services’ proposed rule for Stage 2 of the electronic health records meaningful use program does not mandate use of encryption, but it does emphasize increased consideration of encryption of data at rest in ambulatory and inpatient EHR systems.

Stage 1 meaningful use security requirements rely on HIPAA security rule provisions under federal code 45 CFR. Under HIPAA, encryption is an “addressable” specification, meaning a covered entity decides if it is a “reasonable and appropriate” technical security step to implement. The security rule enables an entity to adopt an alternative protective measure that achieves the same purpose if the alternative is reasonable and appropriate.

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