Contingency plan: backup, disaster recovery, emergency mode, testing

Granite City Family Dental — Policy set version 1.0 — Effective November 1, 2026 — Binder edition 2026

Authority: 45 CFR 164.308(a)(7) (contingency plan): data backup plan (ii)(A), disaster recovery plan (ii)(B), emergency mode operation plan (ii)(C), testing and revision (ii)(D), applications and data criticality analysis (ii)(E).

Approved by Dr. Maria Lindqvist, Owner. Plan owner: Janelle Okafor, Office Manager.

Purpose

This plan keeps Granite City Family Dental seeing patients when the EHR is down, a server is encrypted, the power is out or the office cannot be used, and gets the practice's data back afterward. A backup that has never been restored is a hope, not a plan, so testing is part of the plan.

1. Data backup plan

Authority: 45 CFR 164.308(a)(7)(ii)(A).

Rules:

• Backup jobs run daily without manual steps. CRU Technologies receives the job reports and tells the Security Officer about any failure the same day. A failure that lasts more than two days is an incident under document 16.
• Retention is Daily for 30 days, monthly for 12 months, long enough to reach back before a ransomware infection that went unnoticed.
• Backups contain ePHI and are protected like the systems they copy: encrypted, access limited to the IT provider and the Security Officer, and covered by the backup vendor's business associate agreement.

2. Disaster recovery plan

Authority: 45 CFR 164.308(a)(7)(ii)(B).

Recovery objectives set by the practice:

• Recovery time objective (RTO): 8 hours — the longest the practice can run without the EHR before patient care is harmed.
• Recovery point objective (RPO): 24 hours — the most data the practice can afford to lose and re-enter from paper.

The backup frequency above must be at least as frequent as the RPO, and the restore method must be proven faster than the RTO by the annual restore test.

Recovery steps:

1. The Security Officer declares a disaster when a critical application in the table below is expected to be down longer than the RTO, or the office cannot be used. Emergency mode (section 3) starts at once.
2. CRU Technologies determines the cause and the scope, and chooses between repairing the system and restoring to replacement hardware or a cloud environment.
3. Systems are restored in criticality order (section 5). The most recent clean backup is used; after ransomware, the IT provider confirms the copy predates the infection.
4. Restored data is checked against the last paper schedule and the downtime forms before the EHR is declared live.
5. Downtime documentation is entered into the EHR and the paper forms are filed or shredded under the paper-records rules.
6. The event is logged in the incident log and the contingency test log, and the plan is revised.

Alternate work location if the office is unusable: Dr. Lindqvist's home office with VPN; schedule patients at Sauk Rapids partner office if the building is unusable. Cloud-hosted systems (EHR, email, phones) are reached from any practice-managed device at that location; local systems are restored to replacement hardware there.

3. Emergency mode operation plan

Authority: 45 CFR 164.308(a)(7)(ii)(C).

How care continues at Granite City Family Dental during downtime:

Paper downtime forms for intake, vitals, notes and prescriptions are kept in the downtime binder at the front desk; schedules are printed each morning; after restoration, downtime documentation is entered into the EHR within 2 business days.

• The downtime binder holds this plan, the incident contacts, the printed schedule, blank downtime forms (at the end of this document) and a prescription log.
• PHI is protected the same way during downtime: forms stay in the binder or a locked drawer, are never left in exam rooms, and are collected at the end of each day.
• Only the people who normally have access to records handle downtime forms. The Security Officer may grant temporary access to a system during an emergency; that access is written down and removed when the emergency ends (45 CFR 164.312(a)(2)(ii)).
• Phones: if the phone system is down, the main line 320-555-0142 is forwarded to a practice cell phone.
• Patients are told plainly that systems are down and that their care is being recorded on paper and will be entered into their record.

4. Testing and revision

Authority: 45 CFR 164.308(a)(7)(ii)(D).

• Restore test, at least annually. CRU Technologies restores a sample of files and, where the practice runs a server, a full system, to a test location and confirms it opens and is complete. Last successful restore test: October 18, 2026. What was restored and the result: Restored the Open Dental database to a test folder; opened in 22 minutes; all records present.
• Tabletop exercise, annually. The committee walks through a ransomware scenario and an office-unusable scenario using this plan and document 16, and notes what was missing.
• Downtime drill. Once a year the front desk runs one morning's check-in on the downtime forms, so the forms are familiar before they are needed.
• Results go in the contingency test log; every finding becomes a risk-register item with an owner and a date.
• This plan is revised after every test, every real event, and whenever the EHR, backup vendor, server or office changes.

5. Applications and data criticality analysis

Authority: 45 CFR 164.308(a)(7)(ii)(E).

Systems are restored in this order. Criticality 1 is restored first, within the RTO.

6. Contingency test log

Authority: 45 CFR 164.308(a)(7)(ii)(D). Retain six years.

Approval

Plan approved by: Dr. Maria Lindqvist, Owner Signature: ___________________________ Date: ______________

Security Officer: Janelle Okafor Signature: ___________________________ Date: ______________

Downtime form 1 — Paper patient intake

Granite City Family Dental — Use when the EHR is unavailable. Enter into the EHR within 2 business days, then file or shred under the paper-records policy.

Date: ______________ Time of arrival: ______________ Downtime event: ______________

Patient name: __________________________________________ Date of birth: ______________

Address: __________________________________________ Phone: ______________

Reason for visit: __________________________________________

Insurance carrier and member ID (or self-pay): __________________________________________

Allergies: __________________________________________

Current medications: __________________________________________

Notice of Privacy Practices acknowledged? [ ] Already on file [ ] Signed today [ ] Could not obtain (reason: ______________)

Checked in by: ___________________________ Entered into EHR by: ___________________________ Date: ______________

Downtime form 2 — Paper visit note

Granite City Family Dental — Use when the EHR is unavailable.

Patient name: __________________________________________ Date of birth: ______________

Date of service: ______________ Provider: __________________________________________

Vital signs (BP / pulse / temp / resp / weight / other): __________________________________________

Subjective / history:

__________________________________________________________________________

__________________________________________________________________________

Objective / examination:

__________________________________________________________________________

__________________________________________________________________________

Assessment:

__________________________________________________________________________

Plan, orders and follow-up:

__________________________________________________________________________

__________________________________________________________________________

Provider signature: ___________________________ Date: ______________

Entered into EHR by: ___________________________ Date: ______________ Provider verified entry: ___________________________

Downtime form 3 — Paper prescription and order log

Granite City Family Dental — One line per prescription or order written on paper during downtime. Reconcile against the EHR after restoration so nothing is duplicated.

Reconciled by: ___________________________ Signature: ___________________________ Date: ______________