THE COVENANT HIPAA COMPLIANCE PROGRAM

HIPAA Compliance Task Force
This group is responsible for the assessment and implementation of the final regulations as published in the Federal Register. This task force represents the following areas within The Covenant: Healthcare Management, Account Management, Claims Management, Customer Service, Finance, Human Resources, Network Management, Marketing, Sales, Account Services, Corporate Communications, Quality Control, Corporate Compliance, Facilities, and Information Services and Technology.

Assessment
Our core business applications, regional and national networks, telecommunications systems and infrastructure operations systems, business processes, and policies and procedures have been inventoried.

GAP Analysis
GAP analysis is being performed to determine what technical and administrative requirements are currently in position at The Covenant and to identify policies, procedures, and technical mechanisms that The Covenant needs to implement in order to meet all HIPAA compliance standards.

Implementation
The Covenant will be implementing the ASC X12N 837 v4010 for both professional and institutional claims transmissions, the ASC X12N 834 Enrollment / Disenrollment transmissions, and ASC X12N 276/277 Claim Status Request and Response. Project teams are being assembled to implement new processes, policies, procedures and technical components according to HIPAA's Privacy and Security standards.

Contracts
The Covenant network, software and service vendor agreements are being reviewed and renegotiated as appropriate. Trading Partner, Business Associate, and Chain of Trust agreements are being rolled out to clients, vendors and business associates as appropriate.

Continued Monitoring
Multi-departmental implementation teams will continue to monitor all HIPAA standards and guidelines, including future modifications to the final rules, to ensure corporate compliance. The Covenant is working to make our HIPAA compliance initiatives a seamless transition. The Covenant is confident that our focus and commitment will minimize any impact on client relations and that we will continue to provide the high service levels our clients expect from us.