While the process involved in digital signatures is straightforward, it is far more robust than the electronic signature programs currently used by most healthcare organizations. Cryptography-based technologies are available for inclusion in healthcare systems, but they are rarely used, except in a few commercial products and some academic settings. A public-key management infrastructure, an essential requirement for digital signatures, is not yet available. Although preliminary efforts are underway to establish such infrastructures in the banking and Internet commerce communities, to date, similar efforts have not been seen in the healthcare industry. An effective public-key management infrastructure would be required to certify provider organizations, physicians, nurses, other allied health personnel, and patients themselves.
Significant challenges remain to develop a key management capability that is usable for healthcare.
Obtain copies of the proposed rules and read them carefully. As you do, make notes about how the requirements apply to your organization and any gaps between your current practices and proposed standards. Review the policies and procedures you receive. Assign appropriate individuals to update existing policies and procedures and develop new ones that are needed. Make a comprehensive inventory of the individually identifiable electronic health information your organization maintains.