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Contract 2023-103ADocuSign Envelope ID: OC2D83B1-B5D1-4E9C-ACE9-02C3OB438646 A COLINGTON CONSULTING 2023-103 HELPING ORGANIZATIONS ACHIEVE HIPAA COMPLIANCE"m P.O. Box 10391 1 Burke, Virginia 22009 1844.740.71001 info@cchipaa.com I https://www.cchipaa.com CONTRACT HIPAA COMPLIANCE SERVICES FOR Clermont, Florida Fire Department Colington Security Consulting, LLC d/b/a Colington Consulting (CC) is pleased to offer the following contract for HIPAA Compliance Services to Clermont, Florida Fire Department (CLIENT), a HIPAA Covered Entity. The Client's address: City of Clermont Procurement Services Department 685 W. Montrose Street Clermont, FL 34711 PROJECT OBJECTIVE The objective of this project is to establish and implement a comprehensive compliance program and risk management objectives for the client as specified in the Health Insurance Portability and Accountability Act (HIPAA). Specifically, the project will focus on access to electronic protected health information (ePHI) maintained by the client and assist the client in improving the effectiveness of existing or the implementation of security programs while reducing the potential for security and data breaches. Having a HIPAA Security Risk Assessment and HIPAA Risk Management Plan are required to be compliant with the HIPAA "Security Rule." The purpose of the HIPAA Security Risk Assessment is to determine if proper security safeguards are in place to protect the facility and address employee security policies for those who must access ePHI. This assessment does not guarantee the elimination of all risks associated with ePHI but will include recommendations that, if successfully implemented, should help protect ePHI from natural and environmental hazards as well as unauthorized access. All recommendations are designed to protect the confidentiality, integrity, and accessibility of ePHI. The HIPAA Risk Management Plan (all required HIPAA policies, procedures, forms, logs) will be provided for the sole use and benefit of the Client. CC will provide assistance in implementing this plan. The plan is designed to provide the Client a structure for evaluation, prioritization, and risk -reducing security measures. It also serves as the Client's guidelines for compliance with the required specifications in the HIPAA Security Rule and other related requirements. SCOPE OF ANALYSIS The HIPAA Security Risk Assessment will address existing organizational security safeguards that are currently in place to prevent unauthorized access, tampering, and theft. The scope of the risk assessment will identify the DocuSign Envelope ID: OC2D83B1-B5D1-4E9C-ACE9-02C3OB438646 A COLINGTON CONSULTING HELPING ORGANIZATIONS ACHIEVE HIPAA COMPLIANCET" P.O. Box 10391 1 Burke, Virginia 22009 1 844.740.71001 info@cchipaa.com I https://www.cchipaa.com potential risks and vulnerabilities to the confidentiality, access, and integrity of ePHI that the Client creates, receives, maintains, or transmits. The assessment questions are based on the HIPAA implementation specifications, along with HITECH, Omnibus, and NIST 800 security controls. The assessment will gather data; identify and document potential threats and vulnerabilities; determine the level of risk; identify current security measures; and provide documentation. Policy and procedure requirements found in areas of the assessment will be implemented in the HIPAA Risk Management Plan, which will assist the Client in complying with the established guidelines regarding security safeguard standards as outlined in the HIPAA Security Series. The HIPAA Privacy Assessment will evaluate compliance with the HIPAA Privacy Rule. METHODOLOGY This HIPAA Security Risk Assessment will be accomplished by conducting an accurate and thorough assessment of potential risks and vulnerabilities to the confidentiality, integrity, and availability of ePHI held by the Client. The methodology followed is consistent with the HIPAA Security Series regarding security safeguard standards. The HIPAA Risk Management Plan is the foundation for the HIPAA "Security Rule" compliance efforts. The Risk Management Plan will include written policies and procedures regarding the implementation of security measures which reduce risks and vulnerabilities to a reasonable and appropriate level in compliance with CFR § 45 C.F.R. 164.306(a)(1). Such plan shall include specific procedures for the Client on safeguards necessary to effectively manage any risks or vulnerabilities determined by the HIPAA Security Risk Assessment. DESCRIPTION OF SERVICES 1. A HIPAA Risk Management Plan (HIPAA Policy and Procedures Manual) will be developed. This includes any necessary changes and edits to the plan for one year. The plan will be a PDF version. Needed HIPAA forms, logs, reports, and Security and Privacy Official job descriptions will be provided. The Plan is customized for your organization and does comply with all required areas of the HIPAA Security Rule. The plan will contain 52 sections of policy and procedure that cover all the HIPAA implementation specifications found in the Code of Federal Regulations including a breach notification policy. Any current or draft policies/procedures the Client may have will be incorporated into the plan, if applicable. This plan meets CFR §164.308(a)(1) and CFR § 164.316(a) requirements. Other HIPAA guidance documents will be provided, as necessary. 2. An organizational -wide HIPAA Security Risk Assessment will be conducted. The assessment questions are based on the HIPAA Security Standards and Implementation Specifications, along with HITECH, HIPAA Omnibus Rule, and NIST 800 security controls. This HIPAA Security Risk Assessment will be accomplished by conducting an accurate and thorough assessment of potential risks and vulnerabilities to the confidentiality, integrity, and availability of ePHI held by the Client. The methodology followed is consistent with the HIPAA Security Series regarding safeguard standards. This assessment meets CFR §164.308(a)(1) requirements. 2 DocuSign Envelope ID: OC2D83B1-B5D1-4E9C-ACE9-02C3OB438646 A COLINGTON CONSULTING HELPING ORGANIZATIONS ACHIEVE HIPAA COMPLIANCET" P.O. Box 10391 1 Burke, Virginia 22009 1 844.740.71001 info@cchipaa.com I https://www.cchipaa.com 3. An organizational -wide HIPAA Privacy Assessment will be conducted to evaluate compliance requirements of the HIPAA Privacy Rule. 4. An organization -wide HIPAA Breach Rule Assessment will be conducted. 5. A HIPAA Information Security (InfoSec) Assessment will be conducted. 6. Under the HIPAA Security Standards and Implementation Specifications; Physical Safeguards; Facility Access Controls; CFR § 164.3 1 0(a)(1), a basic Facility Security Plan will be developed and included in the Risk Management Plan. Facility Security Surveys will be conducted for four (4) locations; Fire Administration/Station 1 and Stations 2 - 4. 7. A Contingency/Disaster Recovery Plan will be developed and added as an appendix in the HIPAA Risk Management Plan. This plan meets CFR § 164.308(a)(7) requirements. 8. Conduct an evaluation of the agency's current HIPAA Security Awareness & Privacy Training to determine CFR § 164.308(a)(5) requirements. Provide written findings on the strengths and weaknesses of the current training program. Provide recommendations and guidance for future training programs for Chief Officers and City personnel. 9. Provide a full range of assistance to ensure the organization's HIPAA Privacy & Security Officials have the proper processes and procedures in place to implement and manage a HIPAA compliance program in an operational environment based on the nature of health services being provided. 10. As part of the listed services, provide consultation on HIPAA related issues, as needed, as part of a one- year contract for services. The assessment process reviews the administrative, technical, and physical safeguards in place. We utilize a web -based application for our documentation. Access to the web -based application will be available for the duration of this contract. Asset inventory is a critical component for HIPAA compliance. If requested and not already in place, we can include several spreadsheets for hardware and software asset tracking. PDF versions of all reports are available in the application. Upon conclusion of the assessment process, we issue a HIPAA Compliance Program Report, a HIPAA Privacy Controls Report, a HIPAA Security Risk Assessment (security controls and breach notification) Report, a HIPAA Information Security Report, a Facility Security Survey Report, and a Mitigation Action Plan, if needed. 11. This contract covers the period from October 12, 2023, until October 11, 2024. All services are to be provided remotely. DocuSign Envelope ID: OC2D83B1-B5D1-4E9C-ACE9-02C3OB438646 A COLINGTON CONSULTING HELPING ORGANIZATIONS ACHIEVE HIPAA COMPLIANCET" P.O. Box 10391 1 Burke, Virginia 22009 1 844.740.71001 info@cchipaa.com I https://www.cchipaa.com DELIVERABLES A draft HIPAA Risk Management Plan will be generated and delivered to the Client within 30 days after the risk plan questionnaire is completed and returned. Once the Client reviews the draft Risk Management Plan and provides approval or requested modifications, we shall perform any required revisions and deliver the final HIPAA Risk Management Plan to the Client within 10 days of completing the risk assessments. Upon conclusion of conducting the risk assessment process, written reports will be delivered to the Client within 25 days. MANAGEMENT PRACTICES Those workforce members who have any role involving managing the HIPAA compliance program should be part of the assessment process. The HIPAA Security, Breach, and Privacy Risk Assessments may take up to 2 hours to complete. The date and time of the assessment will be mutually agreed upon by the Client and CC. Once scheduled, additional information will be provided on preparing for the risk assessment process. CONSULTING FEES The total cost for this project, as described under "Description of Services" is $4500.00 Full payment in the amount of $4500 is due upon the execution of this contract. An invoice will be provided for payment. Payment for services can be made by check payable to "Colington Consulting" or by ACH payment process on the invoice. There will be a 3% processing fee added for credit card payments. This is an all-inclusive contract for HIPAA compliance services, as detailed under Description of Services, for providing a full range of assistance in implementing and maintaining a HIPAA Compliance Program. If any additional services are needed beyond the scope of this contract, the billable rate is $175/hour. The client will be notified in writing in advance before any additional work beyond the scope of this contract is undertaken and agreed to by both parties. HIPAA MAINTENANCE SERVICES CONTRACT CC shall provide the Client with an option for a HIPAA Maintenance Services Contract upon conclusion of this current contract. Maintenance Services include reviewing and updates, as needed, to the HIPAA Risk Management Plan (policies and procedures) to meet CFR § 164.316(b)(2)(iii) requirements, conducting the annual assessments, conducting an updated facility security survey, and consultation, as needed, on HIPAA related issues. The fee for HIPAA Maintenance Services contract will be $3600. Please note: This fee may be subject to change based on any additional requirements or services requested by the Client. El DocuSign Envelope ID: OC2D83B1-B5D1-4E9C-ACE9-02C3OB438646 A COLINGTON CONSULTING HELPING ORGANIZATIONS ACHIEVE HIPAA COMPLIANCET" P.O. Box 10391 1 Burke, Virginia 22009 1 844.740.71001 info@cchipaa.com I https://www.cchipaa.com TRAVEL EXPENSES AND TRAVEL TIME FEES There are no travel expenses or travel time fees required for this project. All services are to be provided remotely. INDEMNIFICATION CLAUSE Client shall indemnify and hold harmless CC and its successors, assigns, and affiliates and each of their respective directors, officers, employees, stockholders, agents, and representatives from any third -party loss, liability, claim, damage, or expense (including reasonable attorney fees and legal expenses) suffered or incurred, either directly or indirectly, by any such indemnified party arising from, relating to, in connection with, or otherwise in respect with the products offered and services performed by CC under this contract and agreement. INSURANCE COVERAGE CC maintains professional liability insurance in accordance with the type of work to be performed. Upon request in writing from Client, CC shall provide proof of such insurance. CONFIDENTIALITY AGREEMENT Upon execution of this contract, all recommendations and identified deficiencies, oral and written, communicated to representatives of the Client by CC in the course of the services outlined in this contract and agreement will remain confidential. All information discovered in connection with the services to be provided hereunder will be held in confidence and not discussed, communicated, or transmitted to others. NON -DISCLOSURE AGREEMENT The Client will not, except as authorized or required by the Client's legal and regulatory duties hereunder, reveal or divulge to any person or outside entity any information concerning the content of the completed HIPAA Risk Assessment and Risk Management Plan provided by CC. The Client will keep in complete secrecy all confidential information entrusted to the Client and will not use or attempt to use any such information in any manner which may injure or cause loss, either directly or indirectly, to CC's business interests. The Client can disclose any reports, policy and procedures, guidelines, security procedures, recommendations, or other content contained within the completed HIPAA Risk Assessment and Risk Management Plan for business purposes, such as engaging prospective clients, forging business partnerships, raising capital, at the request of a Covered Entity, and for client's own office or facility implementation. All other disclosures require written consent from CC as long as CC exists and contact with CC can be made in a reasonable time period. The covenants of this paragraph shall be on -going and shall survive without limit even when the products and services offered or contemplated under this agreement and contract have been fully delivered and/or performed by CC. DocuSign Envelope ID: OC2D83B1-B5D1-4E9C-ACE9-02C3OB438646 MI COLINGTON CONSULTING HELPING ORGANIZATIONS ACHIEVE HIPAA COMPLIANCETm P.O. Box 103911 Burke, Virginia 22009 1844.740.71001 info@cchipaa.com I https://www.cchipaa.com SIGNATURE PAGE At your earliest convenience, please sign where indicated below and return a copy of this contract by mail or a scanned copy along with the payment. If mailing, send it to Colington Consulting, P.O. Box 10391, Burke, Virginia, 22009. I �� Jay Hodes President, Colington Consulting October 12, 2023 City of Clermont, FL Accepted Date: 10/12/2023 Freddy Suarez Name: Sue Signature: Title: Procurement Services Director on