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Eight Reasons Why You Need to Audit Your Data Security Plan

September 2, 2016
by By Lee Barrett, Executive Director, EHNAC
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Steps that hospital IT departments to take to ensure they are mitigating risk for their organization

No company is immune to a data breach that could severely compromise your records and your credibility with customers. Every healthcare company should have a data security and privacy plan that identifies potential threats and outlines how to deal with them.

You also should review your plan on a regular basis and have the plan audited by an appropriate agent. Healthcare security consultants, accrediting agencies and others can proactively audit your plans and make suggestions on how to improve.

While it’s highly unlikely that you’ll ever face a federal audit, a significant breach can trigger an investigation that includes your data and security plans. Having a plan may not assuage hefty fines if that plan hasn’t been tested through an audit.

Whether you’re a small provider, large provider, health system, billing company, health plan or healthcare vendor, the advice is the same: you need a plan and you need to audit it.

The eight reasons you need an audit can be divided into two categories: the bad things that can happen if you don’t do an audit, and the good things that can happen if you do.


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First off, the bad:

  1. Think about the literal cost to your business, if your data gets into the wrong hands. In just the first six months of this year, the Office of Civil Rights (OCR) agreed to almost $15 million in settlement payments with covered entities and their business associates. In July alone, the agency compelled two health systems to pay a combined $5.5 million for violations of the Health Insurance Portability and Accountability Act (HIPAA) involving data breaches that affected 13,000 patient records. The fallout from just one corrupted patient data file can be breathtaking; one of the two offending health systems cited in July settled at a cost of $2,000 per record.                                                                                                                                                 

On average, it costs a healthcare organization more than $2.2 million and its business associates more than $1 million for a data breach. Is it worth risking that by taking an “it-can’t-happen-to-us” attitude?

  1. The chance of a data breach is greater than you think. The Ponemon Institute’s latest annual survey on healthcare data privacy and safety found that nine out of 10 healthcare organizations had reported a data breach within the past two years, and 45 percent of the respondents reported more than five such data thefts in that period. And if you’re a private practice or a general hospital, it’s more likely that you’ll sustain HIPAA violations that any other categories of healthcare providers.
  1. A breach won’t just cost you money. It’ll cost you your reputation and the confidence of the people who do business with you. A breach in excess of 500 records must be reported to the OCR, and appears on its public website. Meanwhile, local media and every patient that potentially could be affected must be notified. That kind of negative publicity could create another kind of breach: one of trust between your business partners and customers.
  1. Because even the smallest healthcare providers are using electronic health records systems, issuing prescriptions through digital apps and sharing data electronically with other care partners, a data breach can happen at any place where data is handled or transmitted within your organization. That involves every employee and every interface between electronic systems.

On the other hand, there are four compelling reasons why an audit can be a good thing.

  1. An audit is like life insurance for your business, and it’s not hard to find capable, reputable auditing bodies to perform one. While very small providers can’t afford full-time data security coverage, there are third-party resources available that can help healthcare practices determine the kind of security and privacy plan they need, set up that plan and proactively monitor it to protect those providers in case of a data breach or regulatory audit.
  1. Your data plan, which you can strengthen and validate by the voluntary audit you commission, can be so comprehensive that nothing is left to chance. It can include step-by-step instructions to undertake if a data breach or attack occurs, specific training for all relevant employees and specific responsibilities for business associates who may access sensitive information.
  1. Setting your own audit in motion will help you uncover any data system flaws or breaches that exist before they might come to the attention of the OCR, or the public. In fact, most data breaches (58 percent) are uncovered during audits and assessments.
  1. If you need in-depth auditing and accreditation services to protect your data and attest that it hasn’t been compromised, organizations such as the Electronic Healthcare Network Accreditation Commission (EHNAC) and other third-party organizations can furnish them. The benefits are considerable: in 2012, the Utah Health Information Network (UHIN) was one of just two clearinghouses with zero findings following an OCR audit. UHIN attributed its success to an earlier audit by EHNAC, where UHIN since 2004.

Four carrots and four sticks. Whatever motivation you need, your company must enact a plan for dealing with protected health information. A plan that’s checked regularly, updated periodically and audited occasionally to ensure your data is safe.

Not every provider, clearinghouse, health plan or business associate needs the same type of plan or level of auditing scrutiny, but they all need a data protection plan and an audit to verify it or fill in its coverage gaps. The failure to do so can risk devastating consequences.

What Organizations Are Most at Risk?

According to the OCR, private practices are most likely to be required to take corrective action to achieve voluntary compliance with HIPAA privacy mandates. Compiled from the compliance date (2013 for business associates and 2003 for all other covered entities) the following lists likelihood of a violation, ranked by frequency:

  1. Private practices
  2. General hospitals
  3. Outpatient facilities
  4. Pharmacies
  5. Health plans (group health plans and health insurance issuers)

From the compliance date to the present, the compliance issues investigated most are, compiled cumulatively, in order of frequency:

  1. Impermissible uses and disclosures of protected health information
  2. Lack of safeguards of protected health information
  3. Lack of patient access to their protected health information
  4. Use or disclosure of more than the minimum necessary protected health information
  5. Lack of administrative safeguards of electronic protected health information

Lee Barrett is executive director of the Electronic Healthcare Network Accreditation Commission (EHNAC). He can be reached at lbarrett@ehnac.org.

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Florida Provider Pays $500K to Settle Potential HIPAA Violations

December 12, 2018
by Heather Landi, Associate Editor
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Florida-based Advanced Care Hospitalists PL (ACH) has agreed to pay $500,000 to the Office for Civil Rights (OCR) of the U.S. Department of Health and Human Services (HHS) to settle potential HIPAA compliance failures, including sharing protected health information with an unknown vendor without a business associate agreement.

ACH provides contracted internal medicine physicians to hospitals and nursing homes in west central Florida. ACH provided services to more than 20,000 patients annually and employed between 39 and 46 individuals during the relevant timeframe, according to OCR officials.

Between November 2011 and June 2012, ACH engaged the services of an individual that claimed to be a representative of a company named Doctor’s First Choice Billings, Inc. (First Choice). The individual provided medical billing services to ACH using First Choice’s name and website, but allegedly without the knowledge or permission of First Choice’s owner, according to OCR officials in a press release published last week.

A local hospital contacted ACH on February 11, 2014 and notified the organization that patient information was viewable on the First Choice website, including names, dates of birth and social security numbers. In response, ACH was able to identify at least 400 affected individuals and asked First Choice to remove the protected health information from its website. ACH filed a breach notification report with OCR on April 11, 2014, stating that 400 individuals were affected; however, after further investigation, ACH filed a supplemental breach report stating that an additional 8,855 patients could have been affected.

According to OCR’s investigation, ACH never entered into a business associate agreement with the individual providing medical billing services to ACH, as required by the Health Insurance Portability and Accountability Act (HIPAA) Privacy and Security Rules, and failed to adopt any policy requiring business associate agreements until April 2014. 

“Although ACH had been in operation since 2005, it had not conducted a risk analysis or implemented security measures or any other written HIPAA policies or procedures before 2014. The HIPAA Rules require entities to perform an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of an entity’s electronic protected health information,” OCR officials stated in a press release.

In a statement, OCR Director Roger Severino said, “This case is especially troubling because the practice allowed the names and social security numbers of thousands of its patients to be exposed on the internet after it failed to follow basic security requirements under HIPAA.”

In addition to the monetary settlement, ACH will undertake a robust corrective action plan that includes the adoption of business associate agreements, a complete enterprise-wide risk analysis, and comprehensive policies and procedures to comply with the HIPAA Rules. 

In a separate case announced this week, a Colorado-based hospital, Pagosa Springs Medical Center, will pay OCR $111,400 to settle potential HIPAA violations after the hospital failed to terminate a former employee’s access to electronic protected health information (PHI).

Pagosa Springs Medical Center (PSMC) is a critical access hospital, that at the time of OCR’s investigation, provided more than 17,000 hospital and clinic visits annually and employs more than 175 individuals.

The settlement resolves a complaint alleging that a former PSMC employee continued to have remote access to PSMC’s web-based scheduling calendar, which contained patients’ electronic protected health information (ePHI), after separation of employment, according to OCR.

OCR’s investigation revealed that PSMC impermissibly disclosed the ePHI of 557 individuals to its former employee and to the web-based scheduling calendar vendor without a HIPAA required business associate agreement in place. 

The hospital also agreed to adopt a substantial corrective action plan as part of the settlement, and, as part of that plan, PSMC has agreed to update its security management and business associate agreement, policies and procedures, and train its workforce members regarding the same.

“It’s common sense that former employees should immediately lose access to protected patient information upon their separation from employment,” Severino said in a statement. “This case underscores the need for covered entities to always be aware of who has access to their ePHI and who doesn’t.”

Covered entities that do not have or follow procedures to terminate information access privileges upon employee separation risk a HIPAA enforcement action. Covered entities must also evaluate relationships with vendors to ensure that business associate agreements are in place with all business associates before disclosing protected health information. 


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Eye Center in California Switches EHR Vendor Following Ransomware Incident

December 11, 2018
by Rajiv Leventhal, Managing Editor
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Redwood Eye Center, an ophthalmology practice in Vallejo, Calif., has notified more than 16,000 patients that its EHR (electronic health record) hosting vendor experienced a ransomware attack in September.

In the notification to the impacted patients, the center’s officials explained that the third-party vendor that hosts and stores Redwood’s electronic patient records, Illinois-based IT Lighthouse, experienced a data security incident which affected records pertaining to Redwood patients. Officials also said that IT Lighthouse hired a computer forensics company to help them after the ransomware attack, and Redwood worked with the vendor to restore access to our patient information.

Redwood’s investigation determined that the incident may have involved patient information, including patient names, addresses, dates of birth, health insurance information, and medical treatment information.

Notably, Redwood will be changing its EMR hosting vendor, according to its officials. Per the notice, “Redwood has taken affirmative steps to prevent a similar situation from arising in the future. These steps include changing medical records hosting vendors and enhancing the security of patient information.”

Ransomware attacks in the healthcare sector continue to be a problem, but at the same time, they have diminished substantially compared to the same time period last year, as cyber attackers move on to more profitable activities, such as cryptojacking, according to a recent report from cybersecurity firm Cryptonite.

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Report: 30 Percent of Healthcare Databases Exposed Online

December 10, 2018
by Heather Landi, Associate Editor
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Hackers are using the Dark Web to buy and sell personally identifiable information (PII) stolen from healthcare organizations, and exposed databases are a vulnerable attack surface for healthcare organizations, according to a new cybersecurity research report.

A research report from IntSights, “Chronic [Cyber] Pain: Exposed & Misconfigured Databases in the Healthcare Industry,” gives an account of how hackers are tracking down healthcare personally identifiable information (PII) data on the Dark Web and where in the attack surface healthcare organizations are most vulnerable.

The report explores a key area of the healthcare attack surface, which is often the easiest to avoid—exposed databases. It’s not only old or outdated databases that get breached, but also newly established platforms that are vulnerable due to misconfiguration and/or open access, the report authors note.

Healthcare organizations have been increasingly targeted by threat actors over the past few years and their most sought-after asset is their data. As healthcare organizations attempt to move data online and increase accessibility for authorized users, they’ve dramatically increased their attack surface, providing cybercriminals with new vectors to steal personally identifiable information (PII), according to the report. Yet, these organizations have not prioritized investments in cybersecurity tools or procedures.

Healthcare budgets are tight, the report authors note, and if there’s an opportunity to purchase a new MRI machine versus make a new IT or cybersecurity hire, the new MRI machine often wins out. Healthcare organizations need to carefully balance accessibility and protection.

In this report, cyber researchers set out to show that the healthcare industry as a whole is vulnerable, not due to a specific product or system, but due to lack of process, training and cybersecurity best practices. “While many other industries suffer from similar deficiencies, healthcare organizations are particularly at risk because of the sensitivity of PII and medical data,” the report states.

The researchers chose a couple of popular technologies for handling medical records, including known and widely used commercial databases, legacy services still in use today, and new sites or protocols that try to mitigate some of the vulnerabilities of past methods. The purpose of the research was to demonstrate that hackers can easily find access to sensitive data in each state: at rest, in transit or in use.

The researchers note that the tactics used were pretty simple: Google searches, reading technical documentation of the aforementioned technologies, subdomain enumeration, and some educated guessing about the combination of sites, systems and data. “All of the examples presented here were freely accessible, and required no intrusive methods to obtain. Simply knowing where to look (like the IP address, name or protocol of the service used) was often enough to access the data,” the report authors wrote.

The researchers spent 90 hours researching and evaluated 50 database. Among the findings outlined in the report, 15 databases were found exposed, so the researchers estimate about 30 percent of databases are exposed. The researchers found 1.5 million patient records exposed, at a rate of about 16,687 medical records discovered per hour.

The estimated black-market price per medical record is $1 per record. The researchers concluded that hackers can find a large number of records in just a few hours of work, and this data can be used to make money in a variety of ways. If a hacker can find records at a rate of 16,687 per hour and works 40 hours a week, that hacker can make an annual salary of $33 million, according to the researchers.

“It’s also important to note that PII and medical data is harder to make money with compared to other data, like credit card info. Cybercriminals tend to be lazy, and it’s much quicker to try using a stolen credit card to make a fraudulent purchase than to buy PII data and run a phishing or extortion campaign. This may lessen the value of PII data in the eyes of some cybercriminals; however, PII data has a longer shelf-life and can be used for more sophisticated and more successful campaigns,” IntSights security researcher and report author Ariel Ainhoren wrote.

The researchers used an example of hospital using a FTP server. “FTP is a very old and known way to share files across the Internet. It is also a scarcely protected protocol that has no encryption built in, and only asks you for a username and password combination, which can be brute forced or sniffed

by network scanners very easily,” Ainhoren wrote. “Here we found a hospital in the U.S. that has its FTP server exposed. FTP’s usually hold records and backup data, and are kept open to enable backup to a remote site. It could be a neglected backup procedure left open by IT that the hospital doesn’t even know exists.”

According to the report, hackers have three main motivations for targeting healthcare organizations and medical data:

  • State-Sponsored APTs Targeting Critical Infrastructure: APTs are more sophisticated and are usually more difficult to stop. They will attempt to infiltrate a network to test tools and techniques to set the stage for a larger, future attack, or to obtain information on a specific individual’s medical condition.
  • Attackers Seeking Personal Data: Attackers seeking personal data can use it in multiple ways. They can create and sell PII lists, they can blackmail individuals or organizations in exchange for the data, or they can use it as a basis for further fraud, like phishing, Smishing, or scam calls.
  • Attackers Taking Control of Medical Devices for Ransom: Attackers targeting vulnerable infrastructure won’t usually target healthcare databases, but will target medical IT equipment and infrastructure to spread malware that exploits specific vulnerabilities and demands a ransom to release the infected devices. Since medical devices tend to be updated infrequently (or not at all), this provides a relatively easy target for hackers to take control.

The report also offers a few general best practices for evaluating if a healthcare organization’s data is exposed and/or at risk:

  • Use Multi-Factor Authentication for Web Applications: If you’re using a system that only needs a username and password to login, you’re making it significantly easier to access. Make sure you have MFA setup to reduce unauthorized access.
  • Tighter Access Control to Resources: Limit the number of credentials to each party accessing the database. Additionally, limit specific parties’ access to only the information they need. This will minimize your chance of being exploited through a 3rd party, and if you are, will limit the damage of that breach.
  • Monitor for Big or Unusual Database Reads: These may be an indication that a hacker or unauthorized party is stealing information. It’s a good idea to setup limits on database reads and make sure requests for big database reads involve some sort of manual review or confirmation.
  • Limit Database Access to Specific IP Ranges: Mapping out the organizations that need access to your data is not an easy task. But it will give you tighter control on who’s accessing your data and enable you to track and identify anomalous activity. You can even tie specific credentials to specific IP ranges to further limit access and track strange behavior more closely.


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