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Implementing HIPAA security in a membership organization.

The upcoming HIPAA security regulations are forcing a change in business and operating procedures that many, if not most, healthcare organizations are ill-prepared to tackle. Of all healthcare organizational structures, membership organizations will most likely face the greatest number of obstacles in preparing for and implementing the HIPAA security regulations. This is because the membership organization as a whole must find a way to accommodate the disparate technologies, business and operating methodologies and processes, and available, limited resources of its individual member organizations, and integrate these into a uniform implementation plan. Compounding these obvious difficulties is the unique challenge of enforcement authority. The individual member organizations are autonomous business entities, whereas the membership organization as a whole merely acts as an advisor or consultant, and has only limited enforcement authority over any individual member organization. This article explores this unique situation in depth. We focus on PROMINA Health System, a nonprofit healthcare membership organization that consists of five disparate member healthcare organizations. We examine the challenges PROMINA has encountered in its quest to institute an organization-wide HIPAA security program and its methodology for accomplishing program implementation.