if something like a flood damages the computer and the external hard drive, all that information is compromised. The same concern applies to paper files as well. There has been a trend toward printing out patient records out of fear that cyberattacks could make these files inaccessible. This may be one method to back up data, but if it is the only one, it too is at risk for loss. The remote accessibility of cloud computing also is appealing to the health care industry because it allows information to be shared among health care professionals almost instanta- neously. So long as an individual has Internet access, he or she can access the information. In many cases, if PHI had to be shared from computer to computer, the transferring of informa- tion would take time logistically. Also, if only certain computers in a health

ASCA Resources

ASCA members have free access to ASCA’s HIPAA Workbook for ASCs. The workbook is an ideal resource for designing, evaluating and updating an ASC’s Health Insurance Portability and Accountability Act of 1996 compliance program. In this workbook, and on the Office for Civil Rights web site, ASCs can review guidance on how to create a business associate agreement and what components should be included.

Go to to access the workbook.

care provider’s office are encrypted, the number of computers that could access the information is limited. In addition, if a patient needs to be trans- ferred from an ASC to a hospital, the information on a CSP can be easily accessible through the Internet at the hospital and vice versa.

Cloud computing can be used to store massive amounts of information, including

patient records, radiology

images and test results. Some in the ASC industry use texting and emailing to share PHI. If those systems are linked to a cloud service provider, they also would be subject to this guidance.

Nawa Arsala was previously ASCA’s assistant regulatory counsel. For more information, write Kara Newbury, ASCA’s regulatory counsel, at

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