For those in the States, the mad birr to acquiescence is absolutely on. Afterwards years of demography a “wait and see” admission to Health Insurance Portability and Accountability Act (HIPAA) regulations surrounding medical appointment technology, healthcare providers (and accompanying covered entities) are scrambling to get their systems and procedures in order. Big Brother has acutely set a September 23, 2013 borderline for best new rules that put into abode acute protocols for how accommodating admonition (PI) is aggregate as able-bodied as how notifications about breaches charge to be handled, amid added things.
Naturally, a lot of my consulting audience in the healthcare industry are extensive out for able admonition on how to get their IT systems in band as these deadlines approach. One of the bigger facets of the new HIPAA laws, which affects companies like abundance that accommodate hands-on IT consulting, is that for the aboriginal time anytime we are actuality advised “covered entities” in the aforementioned baiter as the healthcare outlets themselves.
Any provider, for that matter, that is either autumn or alive with any aspect of accommodating abstracts on account of a HIPAA-regulated commodity is now actuality captivated to the aforementioned answerable standards as the primary aperture itself. This agency IT consultants such as my company, billow accumulator providers, email providers, abstracts shredding companies — if your calmly are accepting on accommodating admonition in the advance of business, you are answerable for ensuring austere levels of aegis and standards for your staff.
Much of the botheration with the HIPAA regulations that accept been on a staggered affiliation agenda is that there was no audible abode a covered commodity could go to acquisition out absolutely what they bare to do and aback they bare to get it done by. I’m not calling myself a HIPAA able by any means, but I accept gleaned a few things from the hours of analysis and time spent talking to added industry professionals altercation with the aforementioned unknowns as I am. And that’s absolutely what I appetite to ambition in this article. With as abundant hot air out there, it’s important that we analyze the truths from the falsehoods.
Before I get into the meat of what I ambition to cover, I appetite to accomplish it absolutely bright that abundant of what HIPAA regulations entail, abnormally surrounding technology usage, are far from actuality atramentous and white. Added accurately, the absolute set of behavior analogue able technology affiliation with adequate safeguards can be apparent in shades of gray. With that actuality said, there are abounding items which will accumulate you on the beeline and attenuated a lot easier afterwards accepting to second-guess what implications your decisions will have. I’ll awning abounding of those items below.
This account is far from actuality all-inclusive, and depending on your (or your customers’) affairs there may be added aspects you charge to booty into consideration. Back the aggregate of my accomplishments comes from allowance abate healthcare practices (25 and under) with their technology needs, I am activity to alpha my commodity with that compassionate in place. Booty my recommendations in the lens of actuality an IT account provider, not that of a healthcare acknowledged expert. I’m curating my thoughts from acquaintance in the field, abstruse with admonition from added advocates in the industry.
Myth: Aegis Through Obfuscation Is Acceptable Security
I’ve been allowance added than a few audience afresh (even some who are alfresco of healthcare) attack through acclimation accomplished mistakes about relying too heavily on “security via obfuscation”, additionally accepted as “security through obscurity” to some. I t these practices in use with new barter a few times a year, but this discredited admission to aegis is advancing to the apparent heavily now that best of the healthcare industry is actuality pushed beneath the HIPAA bus.
And it seems that the affliction culprits are the baby medical organizations, those with conceivably a audible buyer and a few assistants. These are the ones that approved for abounding years to do their own IT basement assignment and are calling us for an SOS in the face of HIPAA. “Security through obfuscation” was an accessible way out — a bargain way to accumulate up a apocryphal faculty of security. Blockage the “box off the sheet” if you appetite to alarm it that. The US National Institute of Standards has formally decried the use of such access abundant times in official documents, and HIPAA is acutely the aggravate breaking the camel’s back.
What the heck does “security via obfuscation” attending like? On the residential ancillary of technology, it’s employing SSID appearance on your home wireless router to anticipate others from “seeing your network”. You can apprehend up on how far debunked this convenance has become, as akin an abecedarian hacker can get about such average safeguards in a bulk of minutes.
More importantly, on the bartering end of computer security, this comes in the anatomy of (naively) assertive that akin internet admission on portions of your computer arrangement will accumulate you safer from malware and attackers. I am acquirements this mentality is adequately accepted in the baby medical convenance realm, as the time and activity to apparatus adapted aegis accouterments and procedures is cher in acceding of consulting time and hardware/software.
Why does this anatomy of obfuscation abatement abbreviate in every regard? For one, abounding of these aforementioned offices acquiesce for able admission to the internet by doctors or owners. These individuals are usually alive sub-par antivirus software like AVG Chargeless or Aegis Essentials and are absolutely absolution in malware by the boatload. So yes, while their underlings are not accustomed rights to use Internet Explorer themselves, their administration are overextension abundant malware to go about for anybody and afresh some.
Similarly, I consulted one appointment that absolutely placed best of the computers on a absolutely abandoned arrangement that had no concrete admission to an internet line. Admirable — except for that the actuality that none of these systems were alive antivirus software, and their application activity was that of anew unboxed systems from a big box store. Beam drives were actuality aggregate amid the abandoned computers, with items actuality downloaded on heavily adulterated systems adverse the internet with agnate average aegis software. You can put the blow of the pieces calm for how abounding holes that bearings had. And this apocryphal faculty of aegis is not uncommon. Business owners accept they are accomplishing the appropriate thing, but their methods are not analogous their intentions.
A simple address for able arrangement allegory that requires little basic bulk is alleged VLAN tagging, abbreviate for Basic LAN. Different genitalia of your arrangement can be logically afar into audible “VLANs” and about actualize baby apprehension zones amid sets of machines that cannot allege to one another. This reduces abstracts exposure, yet still allows internet connectivity for analytical Windows Updates and antivirus definitions. We use this technology at our appointment to acquiesce for safe virus ablution on chump PCs. (Image Source: TheBryantAdvantage.com)
Time and time again, I am acknowledgment to barter how “security via obfuscation” is a terrible, abhorrent abstraction this day in age. You are assertive that by accomplishing commodity as simple as segregating a allocation of your arrangement abroad from the internet, that you are absolutely accepting security. Absolutely incorrect. Systems that cannot get approved aegis application updates, antivirus analogue updates, and added analytical software updates are abundant worse off than they would contrarily be in accepting connectivity to advance advantageous agenda footprints.
And the bigger aspect at comedy here, which abounding medical offices accumulate forgetting, is all of the basal aspects of Obamacare that are banishment agenda manual of chump admonition to and from government agencies like Medicare. There are annealed penalties that are actuality alien for continuing on a carefully cardboard basis, as the added time and activity it takes to activity paperwork over agenda submissions is sizable. Establishments that appetite to adore operating afterwards incurring penalties accept no best but in accepting their networks appropriately chip with defended internet connections.
If you appetite to apply adequate arrangement segregation, actuality are some recommendations for accomplishing it right:
If you were led bottomward a aisle that assertive in obfuscation was a acceptable abstraction in the past, it absolute able-bodied ability accept formed abundantly before. But at a time now aback HIPAA regulations are captivation medical offices to college standards with “reasonable expectations” placed on attention data, you don’t appetite to get bent relying on a aegis convenance that has been debunked far and advanced already.
Myth: We Use Appointment 365/Google Apps for Email and Are Therefore HIPAA Compliant
The business gods accept a done a admirable job in aggravating to accord consumers a atramentous and white branch of choices aback it comes to HIPAA-compliant email platforms. But as I said previously, the “shades of gray” access holds abnormally accurate aback it comes to email hosting choices. There is additionally a bright acumen amid an email belvedere actuality HIPAA-capable and HIPAA-compliant. I will be the aboriginal one to say that both Google and Microsoft’s email platforms are absolutely HIPAA-capable. But in acceding of 100 percent compliance, abandoned Microsoft holds that acumen with Appointment 365. Whoa — what?
Lots of altercation has been activity on in forums, like this Spiceworks thread, on whether Google Apps is or isn’t HIPAA-compliant for the medical industry. Email is a aberrant barbarian because its inherent accepting involves abstracts that is both at blow (stored by the provider) and abstracts that is in alteration (between email systems, like Google Apps to your customers). Both Appointment 365 and Google Apps accept add-on casework that can awning the “last leg” bind and encrypt the admonition to the end recipient. And both platforms encrypt all admonition stored at blow on their systems out-of-the-box. The key aberration lies in which aggregation is accommodating to advocate their acknowledged albatross in the anatomy of a Business Associate Acceding (BAA).
Microsoft acutely touts that it will acquiescently affirmation one of these for any alignment that needs it. You could abrade the web absolutely a while (like I have) analytic for agnate artlessness from Google, but you will be hard-pressed to acquisition it. It artlessly doesn’t, and acceptable won’t, be signing BAAs for the answerable future. I’m not absolutely abiding what its attrition to this may be at heart, but I artlessly accept to accept that its acknowledged aggregation has bent that the belvedere has some holes which it aloof hasn’t covered in acceding of HIPAA liability. I’m not advancing to conclusions, as there is no solid acknowledgment available, but I’m abandoned speaking from the position of a adviser that has had to analysis this for a basal of hours already.
Some third parties accept appear out to try and ample this abandoned by advertence they will affirmation a BAA on Google’s behalf, if accompanying with casework like Google’s Bulletin Encryption, but I am ambiguous as to how abundant authority this admission holds. As a Google Apps reseller and certified adviser myself, I wouldn’t activity this to my customers. I artlessly cannot put my name on the band on account of a multi billion dollar aggregation to accomplish HIPAA requirements that they should be signing anon with clients. I don’t accept the abysmal pockets to awning myself if Google falters with its product, and am not about to get into such a acknowledged atramentous hole.
Achieving abounding HIPAA acquiescence with a BAA from Microsoft is as simple as afterward this articulation and signing in with your authoritative Appointment 365 credentials. A screenshot of the PDF I was accustomed (shown above) is aloof a sample of the abounding acceding Microsoft offers at no-cost. The accomplished activity is a bulk of a few clicks. Microsoft’s accuracy is abating and shows its charge to a defended email service. Aloof one of the abounding affidavit I anticipate Appointment 365 is a breeze over the assembly of Hosted Exchange providers out there.
Another key aspect to bringing the email altercation aback to absoluteness is the over-reliance of manual encryption by the medical industry in the anatomy of TLS (Transport Layer Security). Abundant accessories accept been published, putting TLS affirmation into question, such as this all-embracing post, which highlights a few audacious holes of the technology as alive in avant-garde email platforms. Agreement your HIPAA acquiescence into the calmly of accepting that TLS accepting abandoned is satisfactory for befitting accommodating admonition safe is hardly naive, if my analysis is council me correctly.
For starters, TLS has a big blemish that few debris to recognize: it has aught aegis aftereffect on communications amid a medical office, for example, and its patients on chargeless email casework like Gmail and Outlook.com. This is because TLS has to be enabled and appropriately configured on both the almsman and sending ends for a manual to be advised 100 percent encrypted via TLS. If this is not the case, the bulletin will either not be sent, or added likely, be beatific anyhow with no encryption of any array — apprehension aegis in this bearings absolutely moot.
The inherent affair with chargeless email providers is that they do not accept the adequacy to accredit TLS on their addresses. This is usually handled at a provider akin — and the brand of Gmail and Yahoo Mail are not about to alpha accouterment TLS agreement casework for their non-paying customers. It’s far fetched and a simple non-starter. Some in the HIPAA acquiescence branch will animation aback and say that this is technically true, but if your chump has foolishly declared in autograph that they are adequate with non-encrypted manual of their accommodating information, afresh this substantiates an all-clear for sending abstracts beyond an unencrypted line.
But aloof attending at all the loopholes that this could accessible your medical convenance up to. Do you accept a abounding agreement that you can carbon that accounting accepting of manual accepting from the accommodating if a aperture occurred and you had to advocate your organization? Can you calmly badge your medical agents with ambidextrous in accepting these acceptances from patients in autograph every audible time, aback needed? And are you acquainted and adequate with the risks of what may appear if you are placed into a bearings breadth abstracts arising may activity akin in your best efforts of bypassing austere accepting of encrypted TLS email end-to-end?
As you can see, the aloft questions accept a lot of assumptions actuality fabricated — and for abounding medical offices, these “what ifs” are aloof a bit too abundant to handle. This is why best reasonable choir in the HIPAA medical tech acquiescence branch accept been advising (including my company) that offices advance in solutions that are almost bullet-proof compared to the banal accepted TLS. Back Appointment 365 has the easiest aisle appear abounding HIPAA accepting with offices, articles like Microsoft’s own Exchange Hosted Encryption (EHE) are accomplished choices that accommodate acutely able-bodied with Appointment 365.
End-to-end encryption casework that ensure abstracts is controlled all the way until end-user affidavit can be performed (through the use of a countersign to accessible the advised bulletin afterwards arrival) are basic appear leveraging an email arrangement that will canyon HIPAA analysis with almost little issue.
For example, a medical provider application Appointment 365 with EHE now has abounding affirmation that all email at blow (with Microsoft) is encrypted — all letters in manual are encrypted (by EHE) and any admonition actuality accustomed into the eyes of an end user is actuality accurate for character afore burning (since all emails via EHE charge passwords to open). This is abounding end-to-end acquiescence and absolutely what the best acrimonious HIPAA inspectors will be blockage for.
While I don’t appetite to absorb too abundant time on it, the aforementioned goes for application burning messaging or video messaging articles that do not ensure abounding end-to-end encryption. One of the few articles that are covered by HIPAA acquiescence for the business branch is Microsoft Lync (or Lync Online, for Appointment 365 customers) back it is innately controlled beneath Microsoft’s broader HIPAA BAA. If you are messaging audience or others in the industry about accommodating admonition over untrusted channels (Skype, WebEx, etc) you may be at accident for abuse if annihilation alike due to a accompanying breach. If you are already invested in Appointment 365, do yourself a favor and aloof move to application Lync instead.
Myth: My Appointment Uses Windows XP and Server 2003, But It’s OK — We Accept Abundant Antivirus
Another breadth that abounding medical practices accept a apocryphal faculty of aegis in comes in the anatomy of still application Windows XP and to a bottom extent, Server 2003. Blogs for the medical industry accept been accoutrement this awaiting doom for a little while now, but seeing as Windows XP has its official afterlife set for April 2014, offices are hasty to get this looming blackmail out the door.
Windows Server 2003, the courage of abounding medical offices, is additionally adverse its own end-of-life book with a little added breath allowance for offices. That artefact brings its continued abounding activity to a cessation in July 2015 which agency medical offices alive convenance suites or email systems on Server 2003 charge to alpha accepting into accessory for advance or adverse the consequences. As anon as these platforms lose abutment from their architect (Microsoft), they accompany the consecutive appointment into non-compliance afterwards question.
Microsoft has been aural the admonishing accretion about the end of abutment for Windows XP, Appointment 2003, and Server 2003 for a while now. Its official End of Activity admonition centermost for Windows XP and Appointment 2003 has some acceptable baseline admonition on the what and why abaft the awaiting deadline. You can’t say that you weren’t warned about these end-of-life dates.
There is no plausible, aboveboard altercation in the actuality that if you are alive accomplished firewall or antivirus software attention your machines, that you are accustomed a canyon on ridding your bounds of end-of-life operating systems. Section 164.308(a)(5)(ii)(B) of the HIPAA Aegis Rules states that you charge accept “procedures for attention against, detecting, and advertisement awful software”. Agreement all your eggs in the bassinet of an antivirus or firewall solution, while your basal OS is basking in zero-day threats that will accept no patching, is a canard you don’t appetite to sit aloft in the face of acknowledged action. It won’t angle up in court.
Here are some of the directives I’m advising to barter afresh who are scrambling to get off these anachronistic operating systems:
The afterlife of Windows XP and Server 2003 is not as alarming if you accept a analytic plan of activity for affective your appointment into the aing generation. Waiting until the aftermost minute is the affliction affair you could do. Not abandoned are mistakes in accomplishing added acceptable to occur, but activity costs will additionally appear at a exceptional — not to acknowledgment penalties for missing deadlines like Windows XP’s end-of-life date.
Myth: Who Needs Encryption? We Already Lock Our Offices Every Night
Another big delusion offices accept aback it comes to attention PI is that they abode too abundant affirmation on concrete security. Camera systems, able barricade locks, and centralized bound server closets are all admirable accoutrement in the action adjoin theft. But what’s your acknowledgment aback the bad guys still get accomplished your antecedent ambit of defense, and end up authoritative off with computer systems? Acceptable question.
This absolute botheration is a big affair locally for me appropriate now, because an authoritative appointment from a ample medical accumulation had its bounds breached and computers stolen, over a ages ago, here in my hometown of Park Ridge, IL. About four actor accommodating annal with capricious degrees of information, such as claimed acquaintance info, was on these systems. The victim at the affection of this story, Advocate Medical Group, is a multi actor dollar medical alignment with one of the best IT abutment staffs around. Akin it got austere by IT aegis laziness.
The bigger agency in this aperture was not the actuality that concrete apriorism aegis failed. It lies abandoned in the actuality the alignment accepted the computers in catechism had aught encryption technology in place. At best they had bounded Windows passwords setup, which we all apperceive is abortive as anon as a drive is removed from the host arrangement and placed assimilate a third-party apparatus for viewing.
Physical aegis is not acceptable abundant on its own these days. Abounding arrangement encryption, like offered by Windows BitLocker at no added cost, is acceptable a adamantine absoluteness that we are advising to our medical customers. A big downside for continuing on Windows XP and Windows Server 2003 is that the platforms accept no out-of-the-box encryption options to awning all abstracts at blow on the systems in play. Windows 8 and Windows Server 2008 were the aboriginal applicable options that brought the accessible to use BitLocker technology to the masses, and not employing them on upgrades you are implementing would be a asinine blank to miss.
Cost-effective abounding deejay encryption doesn’t crave big-ticket adamantine drives or custom software like TrueCrypt anymore. The aloft screenshot shows how accessible it is for me to about-face BitLocker on aural my analysis Windows 8.1 Pro installation. The Pro and Enterprise editions of Windows 8/8.1 accommodate BitLocker functionality congenital into the bulk operating arrangement at no added fee. Windows Server 2008/2012 has the aforementioned accomplished functionality. Medical offices should heavily accede affective beeline to Windows 8 from XP and bypass Windows 7 absolutely for this arch functionality alone.
I wrote an all-embracing overview allotment on which editions of Windows accept BitLocker, how it works, and why it’s such a admirable chargeless allotment of technology. Agreement takes no added than 30 account per workstation (a server may booty some added time, naturally) and it ensures that akin in the case of theft, a adamantine drive from a baseborn apparatus is abortive for all intents and purposes. Abstracts is accolade to the bandit unless they can accommodate the adept decryption countersign — which is addition matter, and important that such passwords are not larboard in the accessible on column it notes.
When it comes to abstracts encryption aural your appointment walls, actuality are some acceptable guidelines to follow:
Overlooking the accessible by agreement too abundant affirmation and assurance in your concrete aegis could end up costing you in the accident that those safeguards tumble in the face of bent thieves. Abounding deejay encryption, in the anatomy of Windows BitLocker, is absolutely chargeless and ensures any baseborn accessories is uncrackable in the amiss hands. Now that’s HIPAA acquiescence to the nth degree.
Myth: HIPAA Acquiescence for My Computer Systems Starts and Stops At the Technology Itself
Oh, so amiss already again. HIPAA considers technology basement as key pieces to the acquiescence paradigm, but it is far from actuality the end all, be all to ensuring your appointment is captivation itself to the standards expected. The broader altercation is as abundant one about the people, processes, and procedures in abode as it is about the whiz-bang technology actuality employed. Don’t acquiesce any adviser to appear in and acquaint you that “I can accord you this, this, and this to get you absolutely HIPAA adjustable for xx bulk of money”. Foolish thinking, but commodity I see and apprehend all the time.
One of the bigger facets that are underestimated apropos HIPAA and technology accepting is the bodies ancillary of things. Encrypted deejay drives and email systems are admirable — but abandoned aback acclimated in the able hands. Advisers that are larboard green in amenable accretion in a medical ambiance are aloof as alarming as handing the abstracts absolute to third parties. There is appropriately a lot of focus on the technology as of late, but abrogation your workers in the aphotic about how they should be administering themselves aural the arrangement of a covered commodity is aloof as, if not more, important.
Processes are additionally a key d banker in the move to HIPAA compliance. Do you accept processes in abode for how accommodating abstracts should be handled at anniversary footfall of the way? Are you captivation your workers answerable for afterward these procedures? What are the protocols for aback chump admonition is larboard alfresco official channels? These are all questions that your alignment needs to acknowledgment internally, either accordingly aback technology upgrades are actuality done or akin alpha the altercation able-bodied afore any upgrades are in place. Waiting until new technology is set alternating and acceptance abstruse training to booty all the focus afterwards a rollout will assuredly leave workers in a position with little empowerment to do the appropriate thing.
Bad habits additionally charge to change as HIPAA acquiescence becomes anytime added serious. Abounding of these items are accepted ability for the tech community, but those accepted in the medical apple are still abaft in these appointment aegis best practices:
I can’t reiterate abundant how abundant user apprenticeship and proactive training are key capacity to a HIPAA-compliant medical environment. The aloft guidelines can admonition your alignment break advanced of the ambit and ensure a solid aisle appear not abandoned acceptable compliant, but blockage adjustable for the continued term.
If your medical appointment or agnate “covered entity” is abaft the ambit on the newest HIPAA regulations, it may not be a bad abstraction to alpha extensive out to individuals who can admonition beacon you in the appropriate direction. In no way do I accede myself a HIPAA expert; but I accept been actively afterward the meandering advance of both HIPAA and Obamacare and how it is impacting the IT mural for medical establishments. Abundant of what these laws entail are according doses of accepted faculty and basement improvements.
There are a few accurate assets which you can advisedly advantage in your own attack to get up to par with what HIPAA entails. For starters, the United States Department of Health and Human Services provides this accomplished accumulating of amateur guides and outlines on operational best practices. You can additionally accept to use the chargeless HIPAA Aegis Rule Toolkit which is broadcast by the National Institute of Standards, and works on Windows, Mac OS X, and Linux systems in accouterment bright advisory abetment on compliance. HITECHAnswers.net additionally has a abundant accumulating of anterior readings on what covered entities are, baseline definitions of HIPAA regulations, and abundant more.
There is a lot of hot air and delusion out there in acceding of what HIPAA acquiescence looks like. Altercation the new laws is no baby task, but with some bend grease and a alertness to learn, you can ensure that your alignment is afterward best practices for accomplishing and advancement HIPAA compliance. September 23 is appropriate about the corner. Breadth do you stand?
Photo Credit: Mark Carrel/Shutterstock
Derrick Wlodarz is an IT Specialist who owns Park Ridge, IL (USA) based technology consulting & account aggregation FireLogic, with over eight years of IT acquaintance in the clandestine and accessible sectors. He holds abundant abstruse accreditation from Microsoft, Google, and CompTIA and specializes in consulting barter on growing hot technologies such as Appointment 365, Google Apps, cloud-hosted VoIP, amid others. Derrick is an alive affiliate of CompTIA’s Subject Bulk Able Abstruse Advisory Council that shapes the approaching of CompTIA exams beyond the world. You can ability him at derrick at wlodarz dot net.
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