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Underlying the discussion was the shift in how companies (and those who run them) think about risk. At Moment, we're comfortable operating in the fluid and fuzzy front-end of the development process, but we appreciate that it isn't always easy for our clients and their organizations. Thanks to our friends at the IIT Institute of Design and Smart Design for hosting a great event.
When not holding things together at Moment, Brendan is also a certified pilot, avid Formula 1 fan, and a father of three, living in Brooklyn, NY. If you’re like a lot of donors, you may find it tough to think of a grant you could call risky. Yet, these days, some are saying risk is a value that small-staff philanthropy must embrace. For example, The Case Foundation has dedicated an entire campaign to encouraging a fearless approach to finding or funding social problems. Astone finds that one way to understand risk-taking is that the donor gives the organization time and support to create meaningful programs and relationships in response to community needs and feedback instead of outside agendas. In spite of the different definitions of risk, there also seems to be some agreement: The more risk there is, the more potential there is for meaningful change to happen.
Elaine Gast Fawcett helps foundations tell their story, educate their stakeholders, and move their mission forward. True risk would be something along the lines of a foundation repeatedly approaching 10% or higher payouts to solve a problem today, rather than adhering to the bare legal minimum and embracing the perpetuity mindset.
And risk would be the Case Foundation actually giving out substantial grants, rather than telling everyone how they should be fearless. True, and there will always be a tension between the freedom given to the tax-exempt sector and the desire on the part of interested parties to see those tax-advantaged assets used in their preferred manner.
But, to say that their are different meanings of risk is to come close to saying that all definitions of risk are equally valid. The broader point is that there needs to be a mix of holding up truly effective philanthropy and pointing out less effective philanthropy. I think, and hope, that we’re in a time of incredible research and data inquiry in the nonprofit sector.
The HIPAA Risk Analysis is so important that it is the first item defined in the HIPAA Security Rule, a requirement since 2005. Proof of the importance of the HIPAA Risk Analysis is that a similar requirement is in Meaningful Use attestation Core Measure 15 to receive funding through the EHR Incentive Program. Before you begin your HIPAA Risk Analysis the first step is identifying all the ePHI within your organization, and how it moves within your systems and in and out of your systems. Remember that ePHI includes any combination of a patient’s name and their diagnosis or treatment.
Once you identify your risks, you can then prioritize them and budget the resources required to avoid or mitigate risks in accordance with compliance requirements and your organization’s tolerance for risk. Vulnerabilities— The HIPAA Security Rule is broken down into Administrative, Physical, and Technical Safeguards, and over 50% of the rules are Administrative. Likelihood— Looking into a crystal ball won’t help, but you can ask experts familiar with technology equipment, your geographic region, and who have experience with similar organizations to yours. Impact— This can be measured in different ways, including life threatening emergencies, financial losses, liability, customer service failures, and compliance violations and related penalties.  A good rule of thumb is that if the impact is high, an event that has a low likelihood of occurring must be considered. Core Measure 15 for Eligible Professionals requires an SRA related to the electronic Protected Health Information stored in their EHR system.
There has been a lot of confusion about the SRA based on incorrect information provided to practices. Key differences between HIPAA and Meaningful Use are that a HIPAA violation will usually be uncovered through one of the infrequent random HIPAA audits, or, also unlikely, as part of a data breach investigation. The US Department of Health and Human Services offered this advice in response to someone asking if they needed an outside expert to conduct their Security Risk Analysis.
Doing a thorough and professional risk analysis that will stand up to a compliance review will require expert knowledge that could be obtained through services of an experienced outside professional. The newly published HIPAA Omnibus Rule requires every HIPAA Covered Entity to review or modify their security compliance programs. Mike Semel is certified in HIPAA and has been the CIO for a hospital (Covered Entity) and has provided IT support for healthcare providers (as a Business Associate.) Mike is certified in Business Continuity planning and helped develop the CompTIA Security Trustmark. Unfortunately, due to the lack of funding, as of May 2015, no new information will be posted to this site. The first question to ask is whether or not another IVF cycle for you has a reasonable chance of success.
Ovarian cancer is much less common than breast cancer, and occurs in about 1 in 75 women in the general population. In summary, there is no clear data linking one or more IVF cycles to a higher risk of breast cancer or ovarian cancer. As we continue to evolve our thinking about risk and what it means for our clients, the wide-ranging discussion provided a valuable opportunity to better articulate our point of view. A successful product will change, and our clients are beginning to understand that significant risk more often comes from inaction than it does from a single imperfect action. Too often “risk mitigation” means a futile attempt to eliminate risk, rather than a concerted effort to manage risk.


In fact, most funders have grown accustomed to making grants they know (or at least suspect) will succeed.
That’s not the case, said ASF member Jennifer Astone of the Swift Foundation at ASF’s 2012 National Conference. And small-staff philanthropy, because of its modest size and ability to act fast, has a nimbleness that accommodates risk.
For 12 years, she has worked nationally to strengthen the philanthropic and nonprofit sectors as a communications and grantmaking consultant. Risk can certainly be a messy business and as often happens the word itself can mean different things to different people and foundations. And to help grantmakers become more effective and increase impact inherently involves making a judgement regarding certain practices. That work is beginning to reveal what methods and practices are, in fact, the most effective and create the most impact (see CEP, GEO). It forms the basis of your HIPAA compliance program, and should be updated annually or more often if something significant changes within your IT environment.
Also, recent HIPAA enforcement actions have cited a missing or old HIPAA Risk Analysis as the basis for HIPAA penalties and large fines (over $ 1 million.) This is something you need to do— and do well. Depending on the size and scale of your organization, you may need to investigate multiple offices, a data center or online EHR provider, local area networks in your offices, wide area networks between offices, the Internet, and other methods of storing and moving data.
If you had no backup (a vulnerability) then a hard drive failure or power spike (threats) may erase or damage your electronic patient records. Human error, malicious behavior, lack of awareness and training, power failures, communications failures, equipment failures, theft or loss of data stored on devices, viruses and malware, and snooping are all examples of threats that can act on vulnerabilities. The guidance does not mention HIPAA by name, but does refer to the Code of Federal Regulations section for the HIPAA Risk Analysis.
The US Department of Health and Human Services published a Myths and Facts document providing guidance.
More frequent audits of practices attesting to Meaningful Use are taking place, and violations are being enforced through the federal False Claims Act. You need it for HIPAA, to comply with Meaningful Use and avoid severe penalties, and to help you make the right decisions that will help you avoid or respond to a disaster. Semel Consulting offers a managed compliance service called HIPAA SOS, compliance audits, Meaningful Use Security Risk Analysis, and business continuity planning. My fertility specialist is recommending a third cycle, but I’m concerned about the long-term risks from the drugs. The static and weekly content posted since June of 2012 will continue to be available to visitors until the end of March of 2016.
I am assuming because your fertility specialist has suggested it, you must have had good IVF cycles – in terms of the response you had to stimulation and the embryo development. The short-term risks of IVF are likely well known to you and include risks of ovarian hyperstimulation syndrome, deep vein thrombosis, arterial thrombosis and the potential surgical complications from the egg retrieval. Breast cancer is unfortunately very common in the population at large, with an overall incidence of 1 in 8. There is older research data linking the fertility drug clomiphene to an increased risk of ovarian cancer. At the present time studies suggest that there MAY be a link between IVF and a type of ovarian tumour called a borderline tumour (not a true cancer) – but there is no link to ovarian cancer per se. Based on the current available research, it is unlikely that doing a third cycle of IVF will make any difference to your long-term risks. The main task of risk management based on the set of measures (controls), which allow to reduce risk level to affordable value.
But it is obvious that new possibilities inevitably connected to new threats, which may lead to the financial and others losses in the company. In order to keep competitiveness on the market you need to implement economically grounded measures for valuable informational assets.В The increasing quantity of computer crimes, tough requirements from the legislation and regulators, and growing dependency for the business on IT systems continuity - this is not a full list of the problems most of the business facing up at the moment.
Last Wednesday evening, accompanied by fellow Momenteers Peter and Yixiu, we attended a discussion on that very topic  hosted by Smart Design and IIT's Institute of Design.
Now, business models are rapidly evolving, new product development processes are fluid and fuzzy, and customers are overwhelmed with choice. Our role is not to avoid risk— to do so would be a failure to design at all— but rather to understand risk and work with our clients to make intelligent investment decisions.
As digital product designers, our advantage is iterative release cycles that allow constant, sustained product evaluation and improvement over long periods of time. Without some appetite for risk, there is no hope of innovation; risk and innovation are a package deal. Giving out a grant that is 10% less likely to succeed but has a 50% larger upside is not risky. Addressing the money side of the equation will get us much further as a sector than scolding nonprofits for being afraid or for having insufficiently collaborative instincts. For some, spending down or sun setting could be a bold and risky strategy, while others may be torn over striking a balance between funding current needs or preserving their assets for the unknown future.
If it doesn’t, or it avoids making anyone uncomfortable, it just becomes an exercise in supporting the status quo (which, in some cases, may be perfectly fine- but that should be a conscious choice). And wouldn’t pointing this out be the role of an organization that wants to help increase effectiveness and impact?


As that becomes clearer I think it is incumbent upon those of us who care about the philanthropic sector to hold up those best practices, and note where we- and others- fall short.
The HIPAA Risk Analysis is the roadmap you must follow to secure electronic Protected Health Information (ePHI) to ensure that you do not breach its confidentiality, integrity, or availability.
To properly conduct the HIPAA Risk Analysis, you need both the IT skills and experience to view stored data and track the movement of electronic data. It can be in any form – written, images, or voice files—and can hide anywhere in your technology environment, which is now expanded to smartphones, tablets, websites, e-mails, electronic fax systems, voice recorders, and portable storage devices. The failure of a hard drive—which spins thousands of times per minute— can be expected (a high likelihood) and the negative effect on your business (the impact) could be huge, since you would no longer be able to access patient records. In many parts of the country weather events have interrupted business by causing power and communications failures. Two notable recommendations are that you may not use a simple checklist for your SRA, and that you should engage a professional if you want your SRA to survive and audit or investigation. What are the risks associated with IVF and do these risks get greater with each additional cycle?
A number of factors have been identified as potentially increasing a woman’s risk for breast cancer, including a genetic predisposition (a family history of breast cancer or carrying the BRCA 1 or 2 gene), prolonged use of the birth control pill, alcohol consumption, infertility, smoking, obesity, diets high in saturated fats, use of hormone therapies after menopause, number of pregnancies, breast feeding, and socioeconomic status.
These studies suggested that more than 12 cycles of clomiphene may increase ovarian cancer risk. At this time there simply is not enough data to say with certainty that fertility drugs and IVF increase a woman’s risk of getting cancer. Another point to remember is that pregnancy is protective against both breast and ovarian cancer. This means the design of a product’s roadmap is often every bit as important as the design of the product itself. And failure—in philanthropy—means losing money that could have gone to another organization. Still others define it in terms of family culture, such as adding a younger generation member to the board. The Swift Foundation funds First Nations and grassroots organizations in British Columbia, for example, and bases the success of its program not on publicity, but on building relationships of trust with those partners. When you are willing to trust leadership, you create the space for listening to what communities really need,” she said.
If you look at the Case Foundation 990, they explain their rationale for not giving out substantial grants. Looking over our nearly 2500 member foundations there is a wide range of answers to these and other questions and I have no doubt each one feels they are acting prudently. Yes, then the foundation can and should have the freedom to ignore that advice- but they shouldn’t be able to pretend, and act, as if they are pursuing their goal in the most effective fashion. Then you need to guesstimate both the Likelihood that a Threat will take place, and measure the anticipated Impact (negative result.) By combining all the variables into your HIPAA Risk Analysis you can determine if a Risk is Low, Medium, or High.
You may lose the records forever, putting patients at risk, violating accessibility and retention requirements, and lowering the value of your practice. Other vulnerabilities include power, connectivity, unencrypted data, systems stored in unsecure locations, portable devices, access to systems and data, and unprotected software. If you haven’t done a good job with HIPAA compliance, this can create a significant risk to your EHR data. The most concerning long-term risk that may be associated with ovulation induction and IVF is the potential increase in the incidence of cancer, particularly breast and ovarian cancer.
The current research for many of these factors is correlational, and consequently some of these factors may appear to be related to breast cancer when in fact they are not.
However, over the course of the past few years the theory of how ovarian cancer develops has changed.
One of the true beauties of our system is that each funder: you, the Case Foundation and every single one of our members, can set their own strategies and make their own decisions (within the legal requirements) as to how they fund and what they fund.
So, it is easy to determine that you should backup your patient records because the impact of not doing it is so high. As far as IVF and ovulation induction is concerned – the truth is we don’t know if these fertility treatments increase breast cancer risk. The new theory is that ovarian cancer starts in the fallopian tubes and spreads to the ovary. Other risks may not be as obvious, and the only way to determine them is to have complete and accurate information.
There have been conflicting studies – most showing that IVF does not appear to influence the risk of breast cancer. However there was a recent Australian study suggesting that women who do IVF before the age of 24 years may be at increased risk of breast cancer. If this theory is correct, there would seem no way to link ovarian cancer to fertility drugs.



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