Executive HIPAA Commitment & Governance
Millennova Solution operates with the unshakeable premise that healthcare data integrity and patient confidentiality are non-negotiable legal and moral imperatives. We maintain a formalized HIPAA Security and Privacy Governance Board led by our Chief Compliance Officer and Security Architect.
Every workflow—from electronic data interchange (EDI) 837 claim ingestion, certified coder chart reviews, to Federal Independent Dispute Resolution (IDR) docket filings—is governed by zero-trust security controls exceeding HHS Office for Civil Rights (OCR) audit standards.
Business Associate Agreement (BAA) Protocols
As a Business Associate under 45 CFR § 164.502(e) and § 164.504(e), Millennova executes formal, bilateral Business Associate Agreements with all Covered Entities before a single bit of Protected Health Information (PHI) enters our infrastructure.
Key BAA Commitments Guaranteed by Millennova:
- Strict restriction to contractually permitted clinical billing and dispute resolution uses.
- Zero disclosure of ePHI to non-authorized third parties or unauthorized personnel.
- Reciprocal pass-through BAA obligations to all infrastructure subprocessors (AWS GovCloud, accredited clearinghouses).
- Commitment to assist Covered Entities in responding to patient accounting of disclosures.
- Mandatory cryptographic erasure upon contract expiration or written directive.
Clean-Room Delivery Facilities & Physical Safeguards
Our global production centers and Austin operational headquarters implement rigid physical barriers under 45 CFR § 164.310:
Access-Controlled Enclaves
Entry to clinical billing operations floors requires biometric fingerprint and dual-factor RFID keycards. Visitor access is logged and escorted 100% of the time.
Zero-Device Workstations
Operating floors enforce a strict paperless and zero-personal-device policy. Smartphones, recording gear, USB flash drives, and external storage are prohibited.
Air-Gapped & Polarized Screens
Coding monitors feature polarized micro-louver privacy filters preventing visual shoulder-surfing. Printers and physical paper media are completely barred.
24/7 CCTV & Security Logs
Workstation perimeters are monitored with high-resolution CCTV with footage retained for 180 days in tamper-evident secure storage.
Cryptographic Safeguards & Logical Tenant Isolation
Millennova enforces technical controls complying with 45 CFR § 164.312:
- A. FIPS 140-2 Validated AES-256: All data at rest—including relational databases, clearinghouse SFTP queues, and document vaults—is encrypted using AES-256 with KMS keys rotated annually.
- B. TLS 1.3 In-Transit Protocol: All external API endpoints and clearinghouse EDI streams mandate TLS 1.3 encryption with Perfect Forward Secrecy (PFS).
- C. Strict Logical Tenant Isolation: Client data pools are partitioned at the database schema and application layer. Under no circumstances can cross-tenant data leakage occur.
- D. Automated Inactivity Timeout: Workstations terminate active clinical sessions after 10 minutes of inactivity, requiring full credential and MFA re-authentication.
Administrative Safeguards & AAPC / AHIMA Credentials
Technical safeguards are only as strong as human discipline. Millennova requires:
- Rigorous Background Checks: Multi-jurisdiction criminal record checks, drug screenings, and federal OIG/SAM exclusion list verifications for 100% of staff prior to hiring.
- Mandatory HIPAA Recertification: All coders, billers, and engineers complete annual HIPAA/HITECH training certified by our compliance officers.
- AAPC / AHIMA Credentialing: Medical coders maintain active certifications (CPC, COC, CPMA, CCS) with continuing education units (CEUs) paid by Millennova.
Incident Response & Breach Notification SLA
In accordance with 45 CFR § 164.410, Millennova maintains a rapid-response Security Incident Response Team (SIRT):
Internal Containment SLA
Immediate containment, network isolation, and forensic snapshot protocol.
Client Breach Notification SLA
Formal written notice provided to Covered Entity with initial forensic findings.
Immutable Audit Trails & Annual SOC 2 Type II
All interactions with ePHI generate immutable, cryptographically chained audit trails capturing user ID, timestamp, patient identifier, action (read/modify/export), and source IP. Audit trails are streamed to write-once-read-many (WORM) storage and reviewed weekly for anomalous behavioral patterns. Millennova undergoes annual SOC 2 Type II independent audits verifying Security, Availability, and Confidentiality trust service criteria.
Execute an Institutional Business Associate Agreement
Ready to onboard with Millennova? Our legal and compliance division can execute a standard bilateral BAA within 4 business hours:
Request Executed BAA & SOC 2 Type II Summary
Submit your covered entity NPI and authorized signatory credentials. Our legal team will dispatch a mutual BAA via DocuSign immediately.