If we had to reduce all of vendor management down to two operations, we’d suggest a strong contract policy, and a sorting process.

Business Associate Agreements Simplified

For those of you who are wanting to come into lightening-speed compliance with Section 164.308(b)(1) of the HIPAA Security Ruling, start telling your vendors that they need to revise their agreements to include the following:

1. A promise to keep an inventory of sensitive information, and a promise to never disclose such information to third parties without customer’s permission.
2. A promise to, in the event promise #1 is accidentally broken, inform customer within a reasonable amount of time after realizing that vendor’s promise #1 was broken.
3. A promise to implement appropriate controls that will mitigate the risk of promise #2 actually happening.
4. A promise to participate in customer’s due diligence process in order to present evidence that vendor complies with promise #3.

This should be done after you have sorted your vendors into three groups: 1) those vendors who you give information to (they possess it), 2) those vendors who have access to information (like your cleaning people or your network support providers), and 3) everybody else. You can ignore group three.

Have fun! It’s a lot easier said than done!