HomeMy WebLinkAboutResolutions - 2018.02.21 - 23332MISCELLANEOUS RESOLUTION #18060 February 21, 2018
BY: Commissioner Bill Dwyer, Chairperson, Public Services Committee
IN RE: SHERIFF'S OFFICE — CREATION OF TECHNICAL ASSISTANT POSITION FOR HIPAA
COMPLIANCE
To the Oakland County Board of Commissioners
Chairperson, Ladies and Gentlemen:
WHEREAS in 2016, Oakland County Information Technology performed a risk assessment of its
technology to determine compliance with the Health Insurance Portability and Accountability Act (HIPAA)
Security Rule Requirements; and
WHEREAS this assessment included review of the controls, procedures and processes that support
technology used within departments that handle protected health information (PHI) and personally
identifiable information (PII); and
WHEREAS this assessment identified enhancements that should be made to reduce the risk of security
incidents and information loss which could result in financial and reputational harm to Oakland County;
and
WHEREAS the Sheriff's Office was included in the HIPAA Compliance Program due to healthcare
services provided for the jail, benefits administration, and physical examinations for employees; and
WHEREAS the Sheriff's Office has multiple contracted services that are also within the scope of the
compliance program due to access to arrestee Pll and PHI; and
WHEREAS the Sheriff's Office has approximately 1,500 employees, interns, subcontractors and reserve
officers who have varying degrees of access to this PHI and PII; and
WHEREAS to comply with the Oakland County HIPAA Policy and Procedures, delegated department
system administrators must:
• Grant access to electronic and physical forms of PHI based on documented authorizations
• Determine level of access based on individual role and management requests
• Remove access when no longer needed or document exceptions
• Periodically audit system access; and
WHEREAS the risk assessment identified certain findings within the Sheriff's Office including the need to
address periodic access reviews and modifications, documentation of delegated department system
administrator procedures, and security enhancements for the Jail Management System (IMACS) and the
Sheriff's Office network drives; and
WHEREAS the Sheriff's Office currently utilizes one (1) Lieutenant and one (1) Technical Assistant to
maintain general access to systems as well as monitor and maintain specific access to and PII, and
one (1) Lieutenant to monitor and maintain PHI and Pll access to !MACS; and
WHEREAS it has been determined that having one (1) position designated on a full-time basis to monitor
and maintain all PHI and Pll access within the Sheriff's Office would eliminate duplicating efforts as well
as ensuring consistent compliance with HIPAA Policy and Procedures; and
WHEREAS this position would be responsible for:
• Assisting in the development of new processes to comply with HIPAA and other statutes
related to the protection of PHI and PII.
• Implementing new or revised access process.
• Verify current individual access requirements based on work location and update as
necessary.
• Grant, change and remove access to systems containing PHI and Pll within the Sheriff's
Office
• Monitor and maintain system access to PHI and Pll for business associates and contracted
vendors.
• Periodic access review and physical PHI access review audits.
• Create and manage a ticketing system for requests for systems changes.
• Gather and provide control evidence, and develop reports and documentation as requested
by the Sheriff's Office; and
WHEREAS funding for this additional position will be covered by an adjustment to the Emergency
Salaries Reserve budget.
PUBLIC SERVICES COMMITTEE
Motion carried unanimously on a roll call vote.
NOW THEREFORE BE IT RESOLVED that the Oakland County Board of Commissioners approves to
create one (1) GF/GP funded, full-time eligible Technical Assistant position within the Sheriffs Office
Emergency Response & Preparedness Division Administration Unit (#4030501).
Chairperson, on behalf of the Public Services Committee, I move the adoption of the foregoing resolution.
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Commissione WILD_Med, District #14
Chairperson, Public Services Committee
Resolution #18060 February 21, 2018
The Vice Chairperson referred the resolution to the Human Resources Committee and the Finance
Committee. There were no objections.