Under the HITECH Act, the Department of Health and Human Services is mandated to annually issue guidance on the most effective and appropriate safeguards to cover against reasonably anticipated threats to electronic protected health information.

“Reasonably anticipated” are the key words, notes Marissa Gordon-Nguyen, a health information privacy specialist at the HHS Office for Civil Rights. The department expects “reasonableness” to govern information security decisions because it understands that each covered entity operates under different circumstances and faces unique security risks. She spoke during the Safeguarding Health Information conference in Washington.

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