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Exam CIPP-US topic 1 question 154 discussion

Actual exam question from IAPP's CIPP-US
Question #: 154
Topic #: 1
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SCENARIO -
Please use the following to answer the next question:
Miraculous Healthcare is a large medical practice with multiple locations in California and Nevada. Miraculous normally treats patients in person, but has recently decided to start offering telehealth appointments, where patients can have virtual appointments with on-site doctors via a phone app.
For this new initiative, Miraculous is considering a product built by MedApps, a company that makes quality telehealth apps for healthcare practices and licenses them to be used with the practices’ branding. MedApps provides technical support for the app, which it hosts in the cloud. MedApps also offers an optional benchmarking service for providers who wish to compare their practice to others using the service.
Riya is the Privacy Officer at Miraculous, responsible for the practice's compliance with HIPAA and other applicable laws, and she works with the Miraculous procurement team to get vendor agreements in place. She occasionally assists procurement in vetting vendors and inquiring about their own compliance practices, as well as negotiating the terms of vendor agreements. Riya is currently reviewing the suitability of the MedApps app from a privacy perspective.
Riya has also been asked by the Miraculous Healthcare business operations team to review the MedApps’ optional benchmarking service. Of particular concern is the requirement that Miraculous Healthcare upload information about the appointments to a portal hosted by MedApps.
What can Riya do to most effectively minimize the privacy risks of using an app for telehealth appointments?

  • A. Require MedApps to de-identity all patient data.
  • B. Prohibit MedApps from using subcontractors.
  • C. Require MedApps to submit a SOC2 report.
  • D. Engage in active oversight of MedApps.
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Suggested Answer: A 🗳️

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twiny
1 month, 1 week ago
Selected Answer: D
I disagree with the author's selection of "A" as the correct answer: A. Require MedApps to de-identify all patient data. De-identifying all patient data would make sense for research and benchmarking services because it protects privacy by removing identifiable information. But the question specifically asks about minimizing the privacy risks of using an app for telehealth appointments. De-identifying all patient data for telehealth appointments defeats its purpose, as patient data needs to remain identifiable for treatment purposes. For telehealth appointments, the primary purpose is treatment, which necessitates the use of identifiable data. Doctors need access to identifiable patient information to provide treatment. Active oversight (choice D), on the other hand, includes monitoring compliance with the Business Associate Agreement (BAA), conducting periodic audits, and ensuring MedApps implements proper safeguards to comply with HIPAA requirements. Active oversight helps address potential risks as they arise, ensuring continued compliance with privacy and security obligations, making choice D the best answer to the question asked.
upvoted 1 times
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Bhimesh
3 months, 3 weeks ago
Selected Answer: A
A. Require MedApps to de-identity all patient data.
upvoted 1 times
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