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Posted on 02.24.2010

Here’s a Hint: Develop a Crisis Plan Before You Have a Crisis ...especially if you work with protected health information (PHI)

Healthcare marketers need to know that yesterday the U.S. Department of Health and Human Services launched a web site designed specifically to bring attention to companies that have recently experienced a data breach related to protected health information (PHI).


As good stewards of our healthcare brands, we know that any hint or perception of a PHI data breach has the potential to spur a broad and vocal response among the media, not to mention the reaction from patients, providers, payers, board members, investors, and any other partners.  Loyalty is hard won and patient trust is an asset that you can’t afford to risk. The HHS web site is designed to “keep us honest.” And it is just one step in the evolution of HIPAA enforcement and mandates for public notification about PHI data breaches, all of which have gotten a massive shove into the next decade by the HITECH Act. HITECH is the insiders’ name for the section of the stimulus package (the American Reinvestment and Recovery Act; ARRA)  that involves health information technology (HIT). Predictably, the notification requirements go much further than just posting the information on a federal web site. While healthcare CFOs, CIOs, and legal teams have been wrestling with other aspects of HITECH long into the night for months, most have neglected to bring their communications team into the loop. Now that there is a central resource for reporters to follow and regulatory requirements where even the most well intentioned healthcare entity might get their wires crossed, the communications professionals have a definitive role to play. This is a perfect opportunity for healthcare communications teams across America to begin building their crisis communications plans – in conjunction with their stakeholders – before a crisis arrives. If there has to be an issue there is no substitute for being able to frame the issue yourself. In this context, playing defense is a losing proposition. Andrea White specializes in communications issues related to health information technology and the HITECH Act. Look for more blog entries on this subject in coming weeks!

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