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SPRINGCM | SERVING HEALTHCARE 10.2006 HOW SPRINGCM IS SERVING HEALTHCARE OVERVIEW   A New York based psychiatric hospital maintains a record system to manage basic data entry and patient information. However, the organization did not have a central source for patient records, accompanying doctors’ notes, x-rays or other relevant information. IMPLEMENTATION HIGHLIGHTS “SpringCM is a natural fit for those Healthcare organizations that need to improve document processes, collaborate and communicate more effectively both inside and outside the organization — that also need to leverage their existing network infrastructure and realize a rapid return on investment.” Christine Mason, SpringCM CEO • At the end of a patient’s stay, a patient records clerk scans the patient’s records to a local drive. Each record is then uploaded to SpringCM by way of file synchronization technology embedded in the SpringCM solution. • SpringCM pulls a summary form of metadata (also known as indices or key attributes) that includes patient name, social security number, stay number, and doctor’s name from the hospital’s patient record system. • Through SpringCM, the hospital is able to facilitate the process of matching the data in its existing patient record system to each new stay folder. The SpringCM system then assigns the relevant metadata to each document in the stay folder and moves the documents to the appropriate patient records folder. • If no immediate match is found, the SpringCM system alerts an administrator at the hospital who can manually input the metadata directly into SpringCM. • For any future stay, a fully searchable view of all patient files is immediately available for physician, support staff, or claim administrator reference. • In the future the hospital intends to utilize SpringCM to handle claim dispute resolution, human resource records and collaborate in real time with other healthcare providers and specialized care teams around the world. BENEFITS ABOUT SPRINGCM SpringCM is the leader in on-demand document and content management, helping companies of all sizes, both domestically and internationally, transform the way information is managed inside and outside their company walls. SpringCM meets the real need of businesses to manage the explosion of documents and other content types – offering an integrated solution for content capture, storage and search, with complete collaboration, workflow, and document process automation capabilities. Today, customers such as GE Medical Systems, Rush Presbyterian Medical Center and others are utilizing SpringCM's unique solution to solve their document management needs. To see how SpringCM can serve your needs, call 877.362.7273 and speak to an associate or visit www.springcm.com . Increase Efficiency, Streamline Processes Centralize, manage, and share information across a variety of document processes through SpringCM’s on-demand document management solution. • Through SpringCM, the hospital gained instant visibility into the breadth and depth of patient information through a single Web-based environment. As a result, the organization has realized business efficiencies in the form of improved information flow, claims management, HIPAA and SOX compliance. • The organization also realized a rapid return on investment, through an affordable monthly subscription service, without having to purchase additional hardware or software. The ability to leverage its existing hardware and software infrastructure was a winwin scenario. • The ability to streamline routine processes helped the hospital focus on higher value tasks – as a result, the organization has identified other areas in which it could realize process efficiencies. Copyright 2006 | SpringCM | 350 N. Orleans Street, Suite 950 | Chicago, IL 60654 | www.springcm.com | 877.362.7273 SECURITY, PRIVACY AND HIPAA POLICIES SPRINGCM | Committed to Serving the Healthcare Industry 2005 All Rights Reserved | SpringCM 350 N. Orleans Street, Suite 950 Chicago, IL 60654 | T 877.362.7273 | www.springcm.com | 10.2006 SPRINGCM SECURITY, PRIVACY AND HIPAA POLICIES SpringCM extends its commitment to protecting and securing personal data by following the general philosophy found in applicable security regimes, including the Health Insurance and Portability and Accountability Act and its implementing regulations (collectively “HIPAA”), such as adopting appropriate physical, technical and administrative safeguards to protect client confidential and personal information, including data which HIPAA defines as Protected Health Information (PHI). The following applies to SpringCM functionality and safeguards, which will apply to our customers’ data: A. HIPAA The greatest burdens that HIPAA places on covered entities include: I. HIPAA’s Individual Rights Provisions: Allowing an individual access their record on demand and allowing an individual to see a record of when and to whom the record has been disclosed II. III. IV. HIPAA’s Security Rule: Adequately securing Protected Health Information (PHI) HIPAA’s Document Retention Policy: Six year mandatory document retention HIPAA’s Audit Trail Policy: Ensuring identification of who accesses documents and when, where and how Here’s how SpringCM can help you manage your HIPAA compliance obligations: Compliance The documents managed through our system can help a covered entity, or business associate of a covered entity, to timely respond to an individual requests for access, amendment and disclosure accounting. SpringCM’s secure document repository, and powerful search capabilities, allow organizations the ability to electronically store, locate and manage large volumes of documents in a fraction of the time compared to traditional filing processes. For example: • SpringCM enables a covered entity to easily search its entire database and quickly assemble an individual’s entire history of PHI to respond to an access request. • SpringCM helps track disclosures of PHI as certain settings can be modified to track a disclosure to another entity. Along those lines, SpringCM can be used to capture certain data required for an accounting (through keywords) such as a list of persons to whom the document is disclosed, a brief description of the disclosure, the date, etc. • A new document can easily be created, stored and tagged for later retrieval to satisfy amendment requirements when the covered entity agrees to make an amendment to PHII on behalf of the individual. 2005 All Rights Reserved | SpringCM 350 N. Orleans Street, Suite 950 Chicago, IL 60654 | T 877.362.7273 | www.springcm.com | 10.2006 SpringCM On-Demand Content Management Security Rule Compliance HIPAA requires covered entities to implement reasonable technical, administrative and physical safeguards to ensure the confidentiality of PHI. Those safeguards should be appropriate for the size and complexity of the covered entity’s business. To that end, SpringCM provide a sophisticated and comprehensive security model. Our technical controls include: • Technical safeguards to secure client’s personal information where data is hosted. These safeguards include: firewalls, Intrusion Prevention Systems, Secure Socket Layer (SSL) encryption over the public Internet for webfacing applications, authentication for remote access and comprehensive protection against malware (malicious software) at Internet gateways, email gateways, file servers and desktops. SpringCM hardens its servers (i.e., permanently shuts down certain services if not in use) and engages in diligent security patch management to remediate vulnerabilities on servers. • Clients may also audit the SpringCM security programs on an annual basis, subject to applicable client confidentiality and security policies. Our administrative controls include: • Role-based access control policy to restrict access to all computerized information through a strong password system. • Access to software or data is prohibited unless specifically authorized by use of such password and granting of rights by the administrator of the client’s account • Users are only given access to the system resources that contain personal data to the extent necessary to perform their roles. All other access to computer resources requires the approval of the data owner, who is typically a business leader responsible for the business functions supported by that data owner. • Clients should give careful consideration to access granted only to specific areas related to that user’s job function authorize those functions through the covered entity’s Information Security Officer. Our physical controls include: • To protect PHI, SpringCM locates all enterprise data on SpringCM’s state of the art hosting environment located with Qwest Communications, a tier one hosting provider. • • SpringCM regularly performs third-party security audits. Among other features, your data is housed on a fully redundant, highly available, Storage Access Network (SAN) in a restricted access area; access is restricted to by badge reader systems, biometrics access control (handreaders) and a facility guard staff. • • Only SpringCM’s key employees are given access to our system storage at Qwest Communications. SpringCM routinely reviews Qwest’s SAS 70s for our vendor and performs on-site monitoring. Security, Privacy and HIPAA Policies 3 SpringCM On-Demand Content Management Document Retention and HIPAA Compliance Audits HIPAA requires covered entities to retain copies of certain documents for six years. The SpringCM system offers virtually unlimited storage capacity. Because of our document creation profiles, a client can indicate whether a particular document should be stored or deleted after a certain period of time. Again, advanced search capabilities help locate documents in the case that the covered entity was subject to an investigation by the Secretary of Health ad Human Services for HIPAA compliance or subject to another type of court process, such as a subpoena. B. SpringCM Commitment to Privacy and Security SpringCM not only designs functionality that supports privacy and security, but also the company operates in a manner that underscores its importance. For example: Information Security and Privacy Policies • SpringCM has adopted an Information Security Policy and a Privacy Policy that establishes uniform security and privacy standards for SpringCM operations. • SpringCM has based its Information Security Policy on BS7799/ISO, an internationally recognized information security management standard. Administrative Officers • SpringCM has a dedicated centralized information security organization led by its Chief Technology Officer (CTO). The CTO reports directly to SpringCM’s Chief Executive Officer (CEO). Privacy Training • SpringCM conducts privacy and security education across the firm that augments training regarding the confidentiality and security of personal information. Confidentiality Agreements • All SpringCM associates execute a comprehensive confidentiality agreement as a condition of their employment by SpringCM. These agreements impose obligations on SpringCM associates to protect the confidentiality and security of client confidential and personal information, including PHI. Business Associate Agreements and Controller-Processor Agreements to Contractually Protect Transfers of Personal Data • SpringCM is not a covered entity. However, because our business interfaces with and supports different types of covered entities, such as health plans, providers and clearinghouses, we will enter into mutually agreeable business associate agreements (or sub-business associate agreements) when requested by clients. Upon request, we can provide a sample of our standard business associate agreement. • To the extent that SpringCM subcontracts processing activities to third parties, it requires such third parties to execute agreements that establish adequate safeguards around the collection, storage, processing and disposal of client confidential and personal information. If you have any additional questions on SpringCM’s HIPAA, security or privacy policies please contact sales@springcm.com or call 877.362.7273 Security, Privacy and HIPAA Policies 4
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