Given the availability and affordability of encryption technology today, it is difficult for a healthcare organization to justify not using some form of it when transmitting PHI. A number of vendors offer a variety of reasonably priced encryption hardware and software, as well as outsourcing options.
For a smaller practice, there are a number of free or nearly free options, and for larger enterprises, if you don't already have some way to encrypt your e-mail, you better not be sending PHI. Though this is an adressable, I would find it difficult to defend any decision concerning PHI sent over e-mail that doesn't include encryption.
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