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Security Best Practices for Protecting Your HIPAA Compliant Data

Guest post by Manoj Puranik, CEO, Atlantic.Net.

Manoj “Marty” Puranik
Manoj “Marty” Puranik

Augusta University Medical Center reported that it had become a victim of phishing for the second time within a 12-month period although fewer than 1 percent of patients were impacted by the second effort. A trio of cybercrime rings took over 26,000 open MongoDB servers and demanded ransom for the owner to retain the data. A successful intrusion of Medical Oncology Hematology Consultants was detected, with 19,203 compromised patient records; however, by that point, the hackers had been inside the system for 20 days.

Kaleida Health announced that it had been victimized by phishing, with 744 patients affected; actually, though, that was adding to a previous tally – with 3,544 total records accessed. Ransomware brought down Pacific Alliance Medical Center; two months later, the firm said that 266,123 patients were impacted.

What do all of these situations and figures have in common? They are all Health Insurance Portability and Accountability Act (HIPAA) violations that took place in 2017. Also, you don’t want to be that organization. Forget the threat to your credibility (perhaps especially the much-dreaded Wall of Shame; the sheer expense is overwhelming. For any data breach, the average drop in revenue experienced by a healthcare firm is $3.7 million

So, with all that said (i.e., since it is more common than anyone would like, and since these cyberattacks are so incredibly costly), it is only reasonable to look over some HIPAA fundamentals and review security best practices for protecting HIPAA compliant data. With the information you collect, you can strategize implementation of the most strongly protected possible system.

Here are a few tips so that your environment can integrate best practices for securing the protected health information (PHI) that is under your watch:

Encrypt everything

Encryption is critical. Just look at a study published in Perspectives in Health Information Management in 2014. While this research is slightly dated, it is compelling because it is a true big data study that looked at all the breaches of HIPAA-protected files that were currently within the HHS Department’s system. At the time of the report, which used all events through September 22, 2013, 27 million people’s records had been compromised, via successful attacks of 674 covered entities and 153 business associates. Forms of intrusion included hacking, improper disposal, loss, theft, unauthorized access, etc. Breaches occurred in various digital environments both through devices and backends, as well as through hard-copy paper documents.

When you look at the data on types of breaches as pieces of the whole, you see how prominent theft is. Here are the top five types of breach in descending order of volume, with the number of individuals, covered entities, and business associates affected in each case (numbers that have now grown substantially): 1. theft – 12,785,150 people (via 344 CEs and 52 BAs); 2. loss – 7,359,407 people (via 74 CEs and 23 BAs); 3. hacking or IT event – 1,901,111 people (via 59 CEs and 20 BAs); 4. unauthorized access – 1,334,118 people (via 136 CEs and 44 BAs); and, 5. improper disposal – 649,294 people (via 32 CEs and 5 BAs).

The key concern here is that these issues are not just about theft. If it were just about laptops being stolen, that would not be as much of a problem because the criminals would not be able to get anything of them necessarily. All of these cases are ones in which the information on the devices that was stolen was unencrypted. In other words, all you need to do is encrypt that data – and even if it does get stolen, you don’t need to worry about it as a violation.

Assess your risk

Conduct a complete risk assessment of all the elements of your ecosystem that store, process, or transfer ePHI, along with other ways in which your information may be exposed physically. Related to the data center environment (whether it’s internal, third-party or hybrid), you want to ask these questions: Are natural disasters common in the location of the data center? Is there a responsible party associated with all hardware components? Have you assessed the security mechanisms that are now in place and any risks that are present? Have you taken into account all ways in which ePHI is accessed or manipulated within your system? Consider the creation, receipt, maintenance and transfer of this information.

Training is fundamental

It is easy, especially related to electronic protected health information, to become obsessed with the systems and to forget about the huge potential for human error. Your staff must be properly trained, especially since the threat landscape is evolving, with an increasingly sophisticated toolset for accessing the data. A very simple yet devastating mistake that is often made is phishing, when a staff member either clicks on a link or submits data, such as usernames or a Social Security number that, thereby, connects them in to a fraudulent system. It is horrifying but true that something as simple as a fake email could create a point of entry for malware or viruses.

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OCR HIPAA Audits Present an Opportunity to Review Your Own Compliance

Blog picture_8.11.2016As part of an ongoing effort to ensure compliance with the HIPAA Privacy, Security, and Breach Notification Rules, the HHS Office for Civil Rights (OCR) has begun the second phase of audits for HIPAA covered entities. The first phase of the audits was conducted in 2011 and 2012 and evaluated the controls and processes implemented by 115 covered entities in order to comply with HIPAA’s requirements. This second phase of audits builds upon the findings of that first audit, and will address compliance efforts by both covered entities and their business associates.

The second phase of the OCR audits is focused primarily on compliance with HIPAA directives related to privacy, security, and breach notifications. Currently, details about the specific documentation that will be required is unavailable, but the OCR has noted that the audit will only deal with compliance with federal guidelines. Compliance with state regulations will not be addressed at all. Still, even though the specifics of the audit are still under wraps, now is a great time to review your own compliance with HIPAA rules and begin gathering documentation.

The HIPAA Audit Process: An Overview

Earlier this summer, the OCR sent notification to all HIPAA-covered entities requiring them to confirm the contact details for their organization and all business associates that handle protected data by the end of July. Once contact details are confirmed, the OCR will send out preliminary surveys to gather more information about specific organizations and their data protection protocols. From those survey responses, several hundred organizations will be chosen for desk audits, which means that they will be required to submit specific, requested documentation as instructed.

While the Phase 2 audits have many health care executives concerned, the OCR has noted that only several hundred entities will be selected for an audit, and of those, a very small percentage (only about 25 to 50 organizations total) are expected to move on to a full, on-site audit. Still, because there is no way of knowing whether your organization will be selected for audit, you need to prepare and be ready to go should that be the case.

The OCR is quick to point out that the Phase 2 auditing process is not intended to be punitive, and that the purpose is rather to identify best practices and potential weaknesses as a means to provide better guidance to covered entities on how to more effectively comply with HIPAA regulations. That being said, regulators do note that should there be serious deficiencies discovered during the process, then there could be sanctions or other corrective actions taken.

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Another Day, Another EHR Survey

Another day, another EHR survey, and once again it’s about the security of information contained in electronic health records.

Apparently, according to this latest survey, more needs to be done to educate patient consumers of the value of the healthcare technology they encounter in their physician’s offices even though more than 50 percent of respondents said they feel EHRs are better than paper charts. Specifically, in this survey patients feel their personal information contained in the EHR is vulnerable to security breaches or hackers.

The data captured in this survey is not surprising, nor is it anything new. In fact, the following statement came from an April 2011 survey I administered for a major healthcare software vendor and announced to the press:

“While both physicians and patients believe that EHR will help improve the quality of healthcare, both groups have concerns about privacy and the security of EHR.” – April 26, 2011.

Though many people think the burden of educating the public about the benefit of EHRs should be placed on physicians, I disagree with this stance.

Physicians, frankly, are consumers of EHRs, just as patients are. It’s an unfair burden to put a group of consumers in the position of advocates for products they pay to use. In what other commercial industry do the manufacturers and retailers of products leave the education of the product to consumer? Correct me if I’m wrong, but I can’t think of any.

The burden of educating consumers about the value and importance of EHRs should fall to the EHR vendors. After all, the vendors are the experts of their products’ capabilities, not the physicians. Automatically electing physicians into this role is unfair.

When I represented an EHR vendor, we brought our message to physicians and patients. Get patients to realize the value of EHRs and you drive them to persuade their physicians to adopt the systems. Our stance meant we held ourselves responsible for educating the market about our EHRs’ capabilities. We didn’t feel that it was right to put our physician clients in the position of becoming product advocates unless they wanted to be. Advocating our products was our job.

As patients become more familiar with EHRs, they will fear them less, just as happened with online banking and shopping. Familiarity and comfort with these systems have changed and so have consumers’ perception of them; the same will ultimately happen for EHRs.