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Glossary of Key Terms and Acronyms in Health Information Technology

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A

AAPC (American Academy of Professional Coders): The professional association for physician medical insurance coders and billers. They sponsor the Certified Professional Coder exam (CPC).


ACCESS POINT: Radio based device that provides users of wireless devices with access to a local area network (LAN).


ACMGA American College of Medical Group Administrators: An association of highly qualified administrators of group practices.


ACMPE American College of Physician Executives: A credentialing and development arm of MGMA.


AHCPR Agency for Health Care Policy and Research: A federal agency dedicated to improving health care quality.


AHIMA (American Health Information Management System): A community of professionals engaged in health information management, providing support to members and strengthening the industry and profession: See www.ahima.org


AMA American Medical Association: Trade association of practicing physicians.


AMI American Medical International: Troubled international company owning many hospitals: Has mostly divested itself of health insurance programs that were financially unsuccessful.


AMIA (American Medical Informatics Association): The first professional group to issue guidelines for physician patient email.


AMR (Ambulatory Medical Record): A computer system for storing, managing, and retrieving electronic patient health information in the outpatient setting: See also EHR and EMR.


ANSI (American National Standards Institute): The U.S. standards organization that establishes procedures for the development and coordination of voluntary American National Standards.


API: Application Programming Interface


Architecture: This term refers to the structure of an information system and how its pieces communicate and work together: Also see client/server and tiered architecture.


ARRA: American Recovery and Reinvestment Act of 2009


ASCs Ambulatory surgical centers or outpatient surgery centers: Medicare coverage is just beginning for these facilities.


ASHIM (American Society of Health Informatics Managers): The professional association for health information technology professionals. They sponsor the Certified Health Informatics Systems Professional exam (CHISP).


ASP (Application Service Provider): A business that deploys, hosts, and manages access to software applications for multiple parties from a central facility.


ASP: Application Service Provider


ASTM International (American Society for Testing and Materials) http://www.astm.org


ATCB: Authorized Testing and Certification Body


ATNA: Audit Trail and Node Authentication

B

BANDWIDTH: A measure of how much information can be transmitted at once through a communication medium, such as a telephone line, fiber optic cable, or radio frequency.


BBA BALANCED BUDGET ACT OF 1997: Frequently referenced to bring large savings ($115 billion from 19982002) in the Medicare program by restricting physician's reimbursement.


BHIE: Bidirectional Health Information Exchange


BIOINFORMATICS: The science of developing and using computer databases and algorithms to hasten and improve biological—and pharmaceutical—research.


BIOMETRIC AUTHENTICATION: Technology that identifies a person through recognition of unique physical characteristics such as retina, voice patterns, fingerprints, etc.


BLUETOOTH: A protocol designed for short-range wireless communication or networking among a variety of devices.


BROADBAND: A medium that can carry multiple signals, or channels of information, at the same time without interference.


BROWSER: A software program that interprets documents written in HTML, the primary programming language of the Web.

C

CAH: Critical Access Hospital


CBO: Community Based Organization


CCD: Continuity of Care Document (CCR + CDA became CCD)


CCHIT (Certification Commission for Healthcare Information Technology): A voluntary, private sector organization launched in 2004 to certify health information technology (HIT) products such as electronic health records and the networks over which they interoperate


CCHIT: Certification Commission for Healthcare Information Technology


CCR (Continuity of Care Record): A standard specification developed jointly by ASTM International, the Massachusetts Medical Society (MMS), the Health Information Management and Systems Society (HIMSS), the American Academy of Family Physicians (AAFP), and the American Academy of Pediatrics


CCR: Continuity of Care Record


CDA (Clinical Document Architecture): Provides an exchange model for clinical documents and brings the industry closer to the realization of an electronic medical record.


CDA: Clinical Document Architecture


CDO: care delivery organization


CDR: Clinical Data Repository


CDS (Clinical Decision Support): Clinical decision support systems (CDSS) assist the physician in applying new information to patient care and help to prevent medical errors and improve patient safety


CDS: clinical decision support


CDSS: clinical decision support system


CENTERS FOR MEDICARE AND MEDICAID SERVICES (CMS) is a federal agency within the United States Department of Health and Human Services (HHS) that administers the Medicare program and works in partnership with state governments to administer Medicaid, the State Children's Health Insurance Program (SCHIP), and health insurance portability standards.


CERTS Centers for Education and Research Therapeutics: Designed by the FDA modernization program passed in 1997 to provide information to effectively improve the effective utilization of new medical products.


CFR: Code of Federal Regulations


CFs The national "conversion factor" used with the Medicare fee schedule: This is a single national number used by all carriers in calculating payments under the Medicare fee schedule.


CHAIN OF TRUST AGREEMENT: Contract needed to extend the responsibility to protect health care data across a series of sub contractual relationships.


CHAMPUS The federal government's name for its health plan for military dependents.


CHC: Connected Healthcare Community


CHIP CHILDREN'S HEALTH INSURANCE PROGRAM: New legislation signed by President Clinton to expand health insurance to children whose parents earn too much for Medicaid yet not enough for private medical insurance.


CLIA Clinical Laboratory Improvement Act: US Act that requires clinical labs to have an internal quality assurance system


CLIENT/SERVER: A network system in which a dedicated computer (server) handles some data storage and processing tasks for applications used on personal computers or workstations (clients), which tap the server's shared files and processing power as needed


CMIO: Chief Medical Information/Informatics Officer


CMS1450: The uniform institutional claim form.


CMS1500: The uniform professional claim form.


CODE OF FEDERAL REGULATIONS: The official compilation of federal rules and requirements.


COORDINATION OF BENEFITS: Process for determining the respective responsibilities of two or more health plans that have some financial responsibility for a medical claim


COPAYMENTS Money paid to physicians, hospitals and labs, usually at the time of service: It is generally a small sum designed to discourage unnecessary or unneeded services to help control health care costs.


COVERED ENTITY: Under HIPAA, this is a health plan, a health care clearinghouse, or a health care provider who transmits any health information in electronic form in connection with a HIPAA transaction.


CPOE (Computerized Provider Order Entry): A computer application that allows a physician's orders for diagnostic and treatment services (such as medications, laboratory, and other tests) to be entered electronically instead of being recorded on paper


CPT Current Procedural Terminology: An AMA booklet listing by number all office and hospital procedures performed by physicians, it is used by the US government in planning reimbursement


CRM (Customer Relationship Management): Information systems and software that enable an organization to manage customers in an organized way with the objective of building better customer relationships.


CURRENT DENTAL TERMINOLOGY: A medical code set of dental procedures, maintained and copyrighted by the American Dental Association (ADA), and adopted by the Secretary of HHS as the standard for reporting dental services on standard transactions.

D

DATA CONDITION: A description of the circumstances in which certain data is required.


DATA CONTENT: Under HIPAA, this is all the data elements and code sets inherent to a transaction, and not related to the format of the transaction.


DATA DICTIONARY: A list that describes the specifications and locations of all data contained in a system.


DATA ELEMENT: Under HIPAA, this is the smallest named unit of information in a transaction.


DATA MAPPING: The process of matching one set of data elements or individual code values to their closest equivalents in another set of them: This is sometimes called a crosswalk.


DATA MINING: Analyzing information in a database using tools that look for trends or anomalies without knowledge of the data's meaning


DATA REPOSITORY: A database acting as an information storage facility


DATA SYNCHRONIZATION/DATA SYNCING: The process of sending updates between a mobile computing device and a personal computer or application server in order to keep both sets of files synchronized


DATA WAREHOUSE: A large database that stores information like a data repository but goes a step further, allowing users to access data to perform research oriented analysis.


DATABASE SERVER: A computer that stores data centrally for network users: It often uses client/server software to distribute the processing of data among itself and other workstations on the network:


DECISION SUPPORT APPLICATION: A computer program that analyzes data and presents the information so that clinicians can make medical decisions more easily


DCODES: Subset of the HCPCS Level II medical codes identifying certain dental procedures.


DEDUCTIBLE: The portion of the health insurance premium paid by the person receiving the coverage: Use of deductibles is an effort to reduce the overall cost of paying for care to the government or insurance company carrying the health policy.


DESIGNATED CODE SET: A medical code set or an administrative code set that is required to be used by the adopted implementation specification for a standard transaction.


DIGITAL CERTIFICATE: An electronic "certificate" (actually a unique number) that establishes a user's identity when conducting business or other "secure" transactions on a network such as the Internet: See also electronic certificate.


DIRECT DATA ENTRY: Under HIPAA, this is the direct entry of data that is immediately transmitted into a health plan's computer.


DISEASE MANAGEMENT: A coordinated and proactive approach to managing care and support for patients with chronic illnesses such as diabetes, congestive heart failure, asthma, HIV/AIDS, and cancer


DRGs (Diagnosis Related Groups): Medicare's method of paying hospitals based on diagnosis rather than for services given


DSL (Digital Subscriber Line): A technology for delivering high bandwidth Internet service over ordinary copper telephone lines.


DSS (Decision Support System): Computer tools or applications to assist physicians in clinical decisions by providing evidence based knowledge in the context of patient specific data

E

EDI (Electronic Data Interchange): A direct exchange of data between two computers via the Internet or other network, using shared data formats and standards.


EDI TRANSLATOR: A software tool for accepting an EDI transmission and converting the data into another format, or for converting a nonEDI data file into an EDI format for transmission.


EFFECTIVE DATE: Under HIPAA, this is the date that a final rule is effective, which is usually 60 days after it is published in the Federal Register.


EH: Eligible Hospital


EHR (Electronic Health Record): A patient's medical record in a data format that follows a patient to be shared among providers.


ELECTRONIC CERTIFICATE: A unique number that establishes a user's identity when conducting business or other "secure" transactions on a network such as the Internet: See also digital certificate.


ELECTRONIC DATA INTERCHANGE: Refers to the exchange of routine business transactions from one computer to another in a standard format, using standard communications protocols.


ELECTRONIC MEDIA CLAIMS: A flat file format used to transmit or transport claims, such as the 192byte UB92 Institutional EMC format and the 320byte Professional EMC NSF.


ELECTRONIC REMITTANCE ADVICE: Any of several electronic formats for explaining the payments of health care claims.


EMPLOYER IDENTIFIER: A standard adopted by the Secretary of HHS to identify employers in standard transactions


EMR (Electronic Medical Record): A patient's medical record in a data format that is used by one provider on his or her internal software: Data may be exportable to an EHR.


EMR/EHR: electronic medical/health record


ENCRYPTION: Translation of data into a code in order to keep the information secure from anyone but the intended recipient.


ENTERPRISE ARCHITECTURE: A strategic resource that aligns business and technology, leverages shared assets, builds internal and external partnerships, and optimizes the value of information technology services.


ENTERPRISE WIDE NETWORK: A network in which all computers in the various facilities of an organization are connected.
EP: Eligible Professional


ePRESCRIBING / eRX: Computer technology in which physicians use handheld or personal computer devices to review drug and formulary coverage and transmit prescriptions to a printer, EMR or pharmacy: ePrescribing software can be integrated with existing clinical information systems to allow access to patient specific information to screen for drug interactions and allergies.


ETHERNET: Probably the most commonly used standard for local area network (LAN) architecture: It supports data transfer rates of up to 10 megabits per second, although newer systems, called Fast Ethernet and Gigabit Ethernet, support transfer rates of 100 Mbps and 1 gigabit (1,000 megabits) per second, respectively.


EXTRANET: An intranet that allows specified levels of access to authorized, external users.

F

FACA: Federal Advisory Committee Act


FACMGA Fellow of the American College of Medical Group Administrators: A fellow is an administrator who has met the difficult admission criteria to be admitted to the college.


FACP Fellow of the American College of Physicians: A title often used by physicians following their M.D.'s that denotes meeting challenging professional standards in internal medicine, indicating a high level of expertise.


FACS Fellow of the American College of Surgeons: An honorary degree awarded surgeons for professional excellence and having met requirements of full surgical training, certification and taking a special examination.


FAT CLIENT: In a client/server system, a client that performs most of the necessary data processing itself, rather than relying on the server.


FHA Federal Health Architecture


File Server: A computer dedicated to managing the flow of information among networked computers and used as a storage location for data and applications shared by network users.


FIPS: Federal Information Processing Standards


FIREWALL: A security device situated between a private network and outside networks like the Internet


FOA: Funding Opportunity Announcement


FORMULARY: A list of medications (both generic and brand names) that are covered by a specific health insurance plan


FOSS: Free and Open Source/Solutions Software


FQHC: Federally Qualified Health Center

G

GAFs Geographical adjustment factors: Used by Medicare to adjust fee schedules.


GATEKEEPERS The physician (usually a primary care doctor) who determines which services a patient will receive and when and where specialty referrals will occur


GHIA Group Health Insurance Association: Trade association of HMO plans.


GPS (Global Positioning System): A collection of satellites that continuously transmit their positions, allowing GPS receivers to pinpoint their own geographic positions by triangulation


GROUP HEALTH PLAN: A health plan that provides health coverage to employees, former employees, and their families, and is supported by an employer or employee organization.

H

HANDHELD: A portable computer that is small enough to hold in one's hand


HEALTH PLAN: An entity that assumes the risk of paying for medical treatments, i.e.: uninsured patient, self-insured employer, payer, or HMO.


HEDIS Health Employers Data Information Set: A standard used by employers to compare the quality and services offered by health plans, group practices, and hospitals.


HHS (Department of Health and Human Services): US agency that is responsible for all federal health programs.


HIE (Health Information Exchange): The movement of healthcare information electronically across organizations within a region or community


HIE: Health Information Exchanges


HIM: Health Information Management


HIMSS (Healthcare Information and Management Systems Society) Professional association for executive level health information technology consultants and professionals:


HIO: Health Information Organization


HIPAA (Health Insurance Portability and Accountability Act of 1996): A federal law intended to improve the portability of health insurance and simplify health care administration: HIPAA sets standards for electronic transmission of claims related information and for ensuring the security and privacy of all individually identifiable health information.


HIPAA Health Insurance Portability and Accountability Act: A government effort to reduce fraud and abuse, stating that a claim for a service based on incorrect coding can result in civil or monetary penalties.


HIPAA: Health Insurance Portability and Accountability Act


HIT (Health Information Technology): The application of information processing involving both computer hardware and software that deals with the storage, retrieval, sharing, and use of health care information, data, and knowledge for communication and decision making.


HIT: Health Information Technology


HITECH: Health Information Technology for Economic and Clinical Health Act


HL7 (Health Level Seven): One of several accredited standards (specifications or protocols) established by ANSI (American National Standards Institute) for clinical and administrative data


HMO Health Maintenance Organization: capitated prepaid health plans


HOSPICE A facility or program providing day care or support and counseling services for the terminally ill.


HOST: A computer that acts as a source of information or provides functionality for multiple terminals, peripherals, and/or users.


HPSA: Health Professional Shortage Areas


HTML (Hypertext Markup Language): The basic programming language for sites on the World Wide Web


HTTP (Hypertext Transfer Protocol): A language protocol used in communication among Web sites


HYBRID ENTITY: A covered entity whose covered functions are not its primary functions.

I

ICD (International Classification of Disease): International disease classification system developed by the World Health Organization (WHO) that provides a detailed description of known diseases and injuries


IEEE (Institute of Electrical and Electronics Engineering): A professional association that develops and promotes standards


IFR: Interim Final Rule


INTEGRATED HEALTH CARE An organization combining all aspects of health care services in an accountable and coordinated fashion, including physicians, hospitals, outpatient surgical facilities, drugs, ambulances, home care, and other services and providers.


INTEROPERABILITY: The ability of software and hardware on multiple pieces of equipment made by different companies or manufacturers to communicate and work together.


IPA (Independent Practice Association): A group of individual physicians or small group practices banded together to contract to deliver HMO or PPO services


ISP (Internet Service Provider): A company that provides users with access to the Internet and the World Wide Web

J

JCODES: A subset of the HCPCS Level II code set with a high order value of "J" that has been used to identify certain drugs and other items.

L

LAN (Local Area Network): A network consisting of computers that are located in relatively close physical proximity to each other and are connected by wire cables, fiber optic lines, or other physical means


LEGACY SYSTEM: An existing IT system or application, often built around a mainframe computer, which generally has been in place for a long time and represents a significant investment.


LOCAL CODES: A generic term for code values that are defined for a State or other local division or for a specific payer: Commonly used to describe HCPCS Level III Codes.


LOINC: Logical Observations Identifiers, Names, Codes

M

MGMA Medical Group Management Association: Professional association of medical group practices: Mainly structured for medical group administrators.


MPI (Master Patient Index): A database program that collects a patient's various hospital identification numbers, e.g.: from the blood lab, radiology department, and admissions, and keeps them under a single, enterprise wide identification number.


MSAs Medical Savings Accounts: Setting aside money to pay health care costs in plans that are seeking government approval


MU: Meaningful Use

N

NAHIT (The National Alliance for Health Information Technology): Also known as "the Alliance" is a partnership of leaders from all healthcare sectors working to advance the adoption and implementation of healthcare information technology to achieve improvements in patient safety, quality and efficiency


NATIONAL COUNCIL FOR PRESCRIPTION DRUG PROGRAMS: An ANSI accredited group that maintains a number of standard formats for use by the retail pharmacy industry, some of which have been adopted as HIPAA standards.


NATIONAL PROVIDER IDENTIFIER (NPI): The name of the standard unique health identifier for health care providers that was adopted by the Secretary in January 2004.


NATIONAL STANDARD FORMAT: Generically, this applies to any nationally standardized data format, but it is often used in a more limited way to designate the Professional EMC NSF, a 320byte flat file record format used to submit professional claims.


NCPDP TELECOMMUNICATION STANDARD: A NCPDP format designed for use by high-volume dispensers of pharmaceuticals, such as retail pharmacies: The Secretary of HHS adopted Version 5.1 of this format as a standard transaction.


NCVHS: National Committee on Vital and Health Statistics


NHII (National Health Information Infrastructure): Is often used synonymously with NHIN: NHII came before NHIN and is an acronym that encompasses all of the necessary components needed to make EHRs interoperable


NHIN (National Health Information Network): Describes the technologies, standards, laws, policies, programs and practices that enable health information to be shared among health decision makers, including consumers and patients, to promote improvements in health and healthcare


NHIN Nationwide Health Information Network


NIST (National Institute of Standards and Technology): Founded in 1901, NIST is a nonregulatory federal agency within the U.S


NLP: Natural Language Processing


NP: Nurse Practitioner


NPI (National Provider Identifier): The Health Insurance Portability and Accountability Act (HIPAA) of 1996 requires the adoption of a standard unique identifier for health care providers


NPI: National Provider Identifier


NPLANID: A term used by CMS for a proposed standard identifier for health plans: CMS had previously used the terms PayerID and PlanID for the health plan identifier.


NPRM: Notice of Proposed Rulemaking

O

OFFICE FOR CIVIL RIGHTS: This office is part of HHS; HIPAA responsibilities include oversight of the privacy requirements.


OMB: Office of Management and Budget


ONC (Office of the National Coordinator): Is a government agency (part of HHS) that oversees and encourages the development of a national, interoperable (compatible) health information technology system to improve the quality and efficiency of health care


ONCHIT: Office of the National Coordinator for Health Information Technology


OPEN SOURCE: Software in which the source code is available to users, who can read and modify the code.

P

PA: Physician Assistant


PACS: picture archiving and communication systems


PART A The hospital part of Medicare.


PART B The physician payment side of Medicare.


PAs Physician Assistants: Certified and trained professionals now allowed to perform many duties formerly done by physicians, such as physical exams, suturing lacerations and other procedures.


PATIENT RECORD LOCATOR: The electronic means by which patient files are located to assist patients and clinicians to find test results, medical history, prescription data, and other health information: A record locator would act as a secure health information search tool.


PHI: Personal Health Information or Protected Health Information


PHP A prepaid health plan: Take Care and Kaiser Permanente are examples of PHPs.


PHR (Personal Health Record): An electronic application through which individuals can maintain and manage their health information (and that of others for whom they are authorized) in a private, secure, and confidential environment.


PHR: Personal Health Record


PKI (Public Key Infrastructure): A system that uses electronic certificates and various authorities (servers that validate certificates, registrations, etc.) to authenticate each entity in an online transaction.


PMS: Practice Management System


PORTAL: A Web site that offers a range of resources, such as email, chat boards, search engines, content and online shopping.


POS "Point of Service" plans that allow the subscriber to see physicians outside the controlled network: Usually the plans are more expensive, and have significant co pays for out of network services.


PPM Physician Practice Management company: A company that acquires physicians practices and salaries the primary care doctors, contracts for them, hires their employees and so on.


PPS: Prospective Payment System (Medicare Part A)


PPS Prospective Payment System: A federally mandated method of paying hospitals for Medicare recipients' services


PQRI: Physician Quality Reporting Initiative


PRACTICE GUIDELINES Summaries of treatment practices approved on the basis of cost, need and outcomes.


PRACTICE MANAGEMENT SYSTEM (PMR): That portion of the medical office record which contains financial, demographic and nonmedical information about patients.


PRO Professional (Peer) Review Organization: A group of physicians and lay people who review appropriateness of outpatient and inpatient health care.


PROVIDER: A widely used term to describe those persons or entities (such as hospitals) that provide health care to patients: This term is intensely disliked by physicians, who regard themselves as doctors, not "providers."

Q

QA (Quality Assurance): Care is reviewed for appropriateness and quality by group practices, hospitals and now insurers.

R

REC: Regional Extension Center


RELATIONAL DATABASE: A database in which all information is arranged in tables containing predefined fields


RFID (Radio Frequency Identification): Technology that uses tiny chips and antennas to track products and store product information.


RHC: Rural Health Clinic


RHIO (A Regional Health Information Organization): an organization that enables the exchange and use of health information, in a secure manner, for the purpose of promoting the improvement of health quality, safety and efficiency


RHIO: Regional Health Information Organizations

S

SaaS: Software as a Service


SCALABILITY: The ability to add users and increase the capabilities of an application without having to making significant changes to the application software or the system on which it runs.


SDO: Standards Development Organization


SEGMENT: Under HIPAA, this is a group of related data elements in a transaction.


SERVER: A networked computer that manages a specific set of network resources.


SMALL HEALTH PLAN: Under HIPAA, this is a health plan with annual receipts of $5 million or less.


SMART CARD: An electronic device about the size of a credit card that contains electronic memory and, increasingly, an embedded microchip.


SQL (Structured Query Language): A standard command language used to interact with a database.


SURGERY CENTER (or outpatient surgery center): A freestanding ambulatory surgical facility where operations are performed at significant savings to the patients (or their insurance carriers) outside of the hospital setting.

T

T1, T3, T4: Types of transmission lines in the T-carrier telecommunications system that are often used to provide Internet access to larger organizations.


TELEMEDICINE: The use of telecommunications and information technology to deliver health services and transmit health information over distance


THIN CLIENT: In a client/server system, a client with little processing or data storage capability that primarily relies on a central server to perform those functions.


THIRD PARTY ADMINISTRATOR: Business associate that performs claims administration and related business functions for a self-insured entity.


TIN: Taxpayer Identification Number


TRANSACTION: Under HIPAA, this is the exchange of information between two parties to carry out financial or administrative activities related to health care.

U

UB92: An electronic format of the CMS1450 paper claim form that has been in general use since 1993.


UR Utilization Review: A program initiated by groups to ensure proper hospitalization and utilization of high technology services that has now been adopted by insurers to keep an eye on and control healthcare services.


URL (Uniform Resource Locator): A Web address: Each Web page has a unique URL.

V

VALUE ADDED RESELLER: A vendor of EDI data communications and translation services.


VPN (Virtual Private Network): A network that uses public connections, such as the Internet, to link users but relies on encryption and other security measures to ensure that only authorized users can access the network.

W

WAN (Wide Area Network): A computer network that covers a large physical area: A WAN usually consists of multiple local area networks (LANs).


WAP (Wireless Application Protocol): A proposed standard for delivering content to mobile wireless devices such as cellular phones and handhelds.


WASHINGTON PUBLISHING COMPANY: The company that publishes the X12N HIPAA Implementation Guides and the X12N HIPAA Data Dictionary: It developed the X12 Data Dictionary, and that hosts the EHNAC STFCS testing program.


WEP (Wired Equivalent Privacy): A security protocol for wireless local area networks (WLANs) using the 802.11b standard.


WiFi: Another name for IEEE 802.11, a wireless networking standard first ratified in June of 1997 and supported by the largest wireless local area network (WLAN) vendors: WiFi is short for wireless fidelity. IEEE 802.11n is the most recent version, which was released in October of 2009 and supports a maximum data stream of 150 Mbps.


WLAN (Wireless Local Area Network): A LAN that uses radio frequency technology to transmit data over relatively short distances


WML (Wireless Markup Language): Web development language that allows Web sites to format content to fit the small screens and limited storage and processing capabilities of mobile devices.


WORKFORCE: Under HIPAA, this means employees, volunteers, trainees, and other persons under the direct control of a covered entity, whether or not they are paid by the covered entity