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A Leading CISO On The Current Threat Environment: “The Days of Just Protecting the EMR are Gone”

December 14, 2017
by Rajiv Leventhal
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UC Irvine Health’s Sri Bharadwaj discusses the uniqueness of the cybersecurity landscape in Southern California

Being in a healthcare organization that is connected to several major University of California organizations, Sriram (Sri) Bharadwaj, chief information security officer (CISO) and director, information services, at UC Irvine Health (Irvine, Calif.), faces unique cybersecurity challenges compared with his CISO colleagues in other pockets of the U.S. But Bharadwaj says that this distinctiveness has led to a transformed cybersecurity culture at UC Irvine Health, one he hopes can be replicated by other patient care organizations.

In early February, Bharadwaj will be part of an expert panel at Healthcare Informatics’ San Diego Health IT Summit where he and his CISO peers will discuss ransomware risks in the wake of the NotPETYA and WannaCry cybersecurity incidents this year. Bharadwaj recently spoke with Healthcare Informatics Managing Editor Rajiv Leventhal about the current cybersecurity landscape, what threats are most concerning to him, and how being connected to other University of California healthcare organizations is making his job somewhat easier. Below are excerpts from that interview.

How do you see the cyber threat landscape right now in your region? Are things getting better?

The cyber threat landscape has definitely changed. When I look at just the UCs (University of California organizations), or any of the hospitals in our vicinity, they have changed purely for two reasons. First, we have started investing in technologies that help address some of the typical threats that we have seen in our environment. Now, have they been mitigated or remediated? I don’t think so; the threats have morphed into something else now that really needs to be addressed. But if you take a technology that you can use to trap issues at the perimeter rather than at the desktop or endpoint level, now your risk or threat mechanism has shifted to the perimeter rather than to your internal environment. That doesn’t mean the risk has gone away, though.

Second, the insider threats have not gone away; they are becoming more sophisticated in that people are allowing insiders to come through by making an error or mistake where they didn’t know that the threat existed. So you need more intelligent tools to actually understand the threat and then take measures to mitigate it.


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Without giving up your “secret sauce,” what are some strategies you have deployed to better secure your data?

The biggest strategy we have implemented is a culture of security awareness. That’s the biggest thing we have done for quite some time now. The level of engagement we have from leadership has shifted from “It’s a security issue” to “I need to inform someone so that this doesn’t impact my organization.” That shift has helped us mitigate some of the risks we see at the insider threat level. The second thing we have done is make considerable investments in tools such as FireEye that allow us to take a look at things from a higher level perspective while also allowing us to share with others.

The FireEye deployment was actually done at the UC level, meaning at the UC Office of the President level, so it applies for all of the UC healthcare organizations. That level of engagement with the Office of the President allows us to look at threats and share threats across the UCs rather than with just one single UC at a time. That’s a big benefit for us.

How unique is this sharing process in your region compared with what goes on in other pockets of the country?

Not only is this unique, but we have also started sharing this information with health systems outside of the UCs. So for example, if there is a threat I see, we now have a relationship with all of the hospitals around us to help them make sure something we see won’t hit them. We have our [annual] CIO Forum with other CIOs in the region that allows all of the CIOs [in this area] to collaborate and figure out how to mitigate threats outside of just one single health system. And that allows us to fortify ourselves in a way so that we have a more robust threat protection rather than being in a reactive mode where you are addressing a threat after you have been hit.

The other thing we have done well is engage with the board at the local and regional levels. We have had conversations with CEOs and compliance officers who have had conversations with other hospital CEOs and compliance officers in this area. And that has created a big advantage for us. Facilitating those conversations gets everyone to understand the issues and understand why we are doing X, Y or Z.

Our conversation with the board started with explaining to them our threats and telling them how we’re doing. We do assessments every year through an external third party, and that assessment done at our level is shared among all of the UCs. And the assessment is used to identify areas of improvement across the organization. We also then look at the tools we deploy and how we could become better at improving our scores.

Three years ago our score was in the 40s or 50s, and now it’s in the top-5 percentile of hospitals across the U.S. Other UCs are applying to get there, but we have gotten there first. So there is definitely a different level of engagement at the senior C-suite level that is helping us [get better]. I also present at our compliance committee to help the [board] understand what these threats are. And almost all the time the question we get asked most is, “What else can we be doing to better protect ourselves?” If that is the level of engagement you are having with the C-suite then you should have no problem identifying either a resource or infrastructure need that you might have.

What are the biggest threats that keep you up at night, as it stands today?

The one area I am most worried about right now is around medical devices. Medical devices are vulnerable purely because of the way they are supported, the way they are put to use, and how the devices are managed. Those are things we need to evaluate.

The other threat is with the new and pervasive devices that our doctors want to use in the [healthcare] environment so they can provide the best care and do what’s best from a population health management standpoint. From a gut feel perspective, you know for sure that you will be addressing a different level of an environment that you now need to prepare for. The days of “everything is in the EMR” are gone, so that means the days of “just protecting the EMR” are gone, too. You have to now look at the broader application portfolio, including medical devices. For example, let’s say you have a network infrastructure that’s segmented in a way so you can identify threats coming from these devices and how they traverse the network. Many hospital organizations don’t have that today and that’s a big issue that we need to hit once we identify the challenges with some of these medical devices.

What advice can you offer for your CISO colleagues who are struggling?

Keep your employees engaged. And that does not just mean asking them to take a course, but I am talking about making security part of the fabric and part of the culture. See something, say something. That’s what we expect our people to do and that’s what is protecting us.

Phishing is very common. Our CEOs and CFOs send me emails every time they believe something could be a phishing message. They are now cautious about opening all emails that might look suspicious; that’s the level we have gotten to. They have realized that they are part of my perimeter and the framework.

The other thing we did is a social engineering mock test where we had the help desk call someone [in the organization] and ask for his or her user ID and password. That test spread like wildfire; we started with one department and in an hour all departments knew about it and started warning others about this caller. That level of engagement we have with our employees really helps keep us on guard. I would tell every CISO to do this.

Finally, I would advise to have that conversation with your C-suite and allow them to understand the threats. Be transparent and open, and help them understand the numbers. CISOs tend to be the technical guys in their own departments, but you should help the board understand that the reason you are there is to protect them. A car going at 65 MPH is going great because you always know that you have the breaks. Your board is going 65 MPH because they rely on you as a CISO to put the right controls in place to make sure they are protected. Show them how you do it.

Can you offer one cybersecurity prediction for 2018?

I have a strange feeling that medical devices will be the next wave to hit us. There will be a worm or something that is released through one of these devices. Some of them are made by companies that are not normally focused on security as a main priority, and there is nothing wrong with that—they are medical device manufacturers. We don’t know as an industry how many of these devices are out there, what OS (operating system) they are running, or if they have already been compromised and are gathering data sitting inside the network. These medical devices are lurking monsters in the back end.

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Healthcare’s “RegTech” Opportunity: Avoiding a 2008-Style Crisis

September 21, 2018
by Robert Lord, Industry Voice, Co-Founder and President of Protenus
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In the financial crisis of 2007 to 2009, the financial industry suffered a crisis of trust. A decade later, banks and other financial institutions are still working to regain the confidence of consumers and regulators alike. In 2008 and 2009, while working at one of the world’s top hedge funds, I had a front-row seat to the damage that occurred to our economy, watching as storied corporate institutions fell or were gravely damaged. Today, as co-founder of a health technology company, I see healthcare is approaching a similarly dangerous situation. We must get ahead of the curve to avoid disaster.

Like finance, healthcare is a highly-regulated industry where non-compliance can result in severe financial and reputational consequences for healthcare companies, and severe impact on people’s lives. We deal with HIPAA, MACRA, HITECH, and hundreds of other foreboding acronyms on a daily basis. A lot of attention goes to the terrific and important work of clinical decision support, wellness apps, and other patient care technologies, but problems in the back office of hospitals must be addressed as well. One of these problems is the amount and complexity of healthcare regulation, and our healthcare system’s inability to keep up.

In finance, where I spent the early part of my career, the adoption of what is termed “RegTech” (regulatory technology) was driven by the increasing complexity of financial technology and infrastructure sophistication.  As trades moved faster, and as algorithms, processes and organizations became more complex, the technologies needed to ensure regulatory compliance had to move in tandem.  The crisis we experienced in 2008 was partially the result of the inability of the industry’s regulatory capabilities to keep up with the pace of technological change.  In many ways, the industry is still playing a catch-up game.

As healthcare professionals, looking to the lessons learned by our colleagues in finance can help us predict patterns and stay ahead of the curve. Right now, I’m seeing alarming parallels to challenges faced in finance a decade ago.


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Robert Lord

The burden of regulation across our industry is simply staggering.  Thirty-nine billion dollars of regulatory burden is associated with healthcare annually, which is about $1,200 per patient, per year. Despite this high cost, we still have $1 trillion of fraud, waste and abuse in our healthcare system. With so much regulation, why are we seeing so little yield from that burden? In many cases, it’s because we’re merely checking boxes and not addressing core risks؅. Like finance, there was a great deal of effort on compliance with regulations, but not enough attention on addressing important systemic risks.

This is not to say I am against good regulation; in fact, many regulations serve to protect patients and improve care. The problem is that there are so many demands on healthcare systems, that compliance and regulation is often reduced to checking boxes to ensure that minimum defensible processes are built, and occasionally spot-checking that things look reasonable. We currently have nowhere near 100 percent review of activities and transactions that are occurring in our health systems every day, though our patients deserve nothing less. However, unless overburdened and under-resourced healthcare providers and compliance professionals can achieve leverage and true risk reduction, we’ll never be able to sustainably bend our compliance cost curve.

Systemic problems are often not discovered until something goes horribly wrong (e.g., Wall Street every decade or so, the Anthem data breach, etc.). Today In the financial industry, RegTech provides continual, dynamic views of compliance or non-compliance and allows management, compliance professionals and regulators to check compliance in real-time. They can view every record, understand every detail, and automate investigations and processes that would otherwise go undetected or involve lengthy and labor-intensive reviews.

The real promise of these new capabilities is to allow compliance professionals and regulators to perform the truest form of their jobs, which is to keep patient data secure, ensuring the best treatment for patients, and creating sustainable financial models for healthcare delivery. RegTech will open up lines of communication and help create conversations that could never have been had before—conversations about what’s not just feasible for a person to do, but what’s right to do for the people whom regulation seeks to protect.

No longer bound by limited resources that lead to “box-checking,” compliance officers can use new and powerful tools to ensure that the data entrusted to them is protected. At the same time, healthcare management executives can be confident that the enterprises they manage will be well served by risk reducing technological innovation.  Patients, the ultimate beneficiaries of healthcare RegTech, deserve as much.

Robert Lord is the co-founder and president of Protenus, a compliance analytics platform that detects anomalous behavior in health systems.  He also serves as a Cybersecurity Policy Fellow at New America.


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HIPAA Settlements: Three Boston Hospitals Pay $1M in Fines for “Boston Trauma” Filming

September 20, 2018
by Heather Landi, Associate Editor
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Three Boston hospitals that allowed film crews to film an ABC documentary on premises have settled with the U.S. Department of Health and Human Services, Office for Civil Rights (OCR) over potential violations of the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule.

According to OCR, the three hospitals—Boston Medical Center (BMC), Brigham and Women’s Hospital (BWH) and Massachusetts General Hospital (MGH)—compromised the privacy of patients’ protected health information (PHI) by inviting film crews on premises to film "Save My Life: Boston Trauma," an ABC television network documentary series, without first obtaining authorization from patients.

OCR reached separate settlements with the three hospitals, and, collectively, the three entities paid OCR $999,000 to settle potential HIPAA violations due to the unauthorized disclosure of patients’ PHI.

“Patients in hospitals expect to encounter doctors and nurses when getting treatment, not film crews recording them at their most private and vulnerable moments,” Roger Severino, OCR director, said in a statement. “Hospitals must get authorization from patients before allowing strangers to have access to patients and their medical information.”

Of the total fines, BMC paid OCR $100,000, BWH paid $384,000, and MGH paid $515,000. Each entity will provide workforce training as part of a corrective action plan that will include OCR’s guidance on disclosures to film and media, according to OCR. Boston Medical Center's resolution agreement can be accessed here; Brigham and Women’s Hospital's resolution agreement can be found here; and Massachusetts General Hospital's agreement can be found here.

This is actually the second time a hospital has been fined by OCR as the result of allowing a film crew on premise to film a TV series, with the first HIPAA fine also involving the filming of an ABC medical documentary television series. As reported by Healthcare Informatics, In April 2016, New York Presbyterian Hospital (NYP) agreed to pay $2.2 million to settle potential HIPAA violations in association with the filming of “NY Med.”

According to OCR announcement about the settlement with NYP, the hospital, based in Manhattan, violated HIPAA rules for the “egregious disclosure of two patients’ PHI to film crews and staff during the filming of 'NY Med,' an ABC television series.” OCR also stated the NYP did not first obtain authorization from the patients. “In particular, OCR found that NYP allowed the ABC crew to film someone who was dying and another person in significant distress, even after a medical professional urged the crew to stop.”

The OCR director at the time, Jocelyn Samuels, said in a statement, “This case sends an important message that OCR will not permit covered entities to compromise their patients’ privacy by allowing news or television crews to film the patients without their authorization. We take seriously all complaints filed by individuals, and will seek the necessary remedies to ensure that patients’ privacy is fully protected.” 

OCR’s guidance on disclosures to film and media can be found here.

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Independence Blue Cross Notifies 17K Patients of Breach

September 19, 2018
by Rajiv Leventhal, Managing Editor
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The Philadelphia-based health insurer Independence Blue Cross is notifying about 17,000 of its members that some of their protected health information (PHI) has been exposed online and has potentially been accessed by unauthorized individuals.

According to an article in HIPAA Journal, Independence Blue Cross said that its privacy office was informed about the exposed information on July 19 and then immediately launched an investigation.

The insurer said that an employee had uploaded a file containing plan members’ protected health information to a public-facing website on April 23. The file remained accessible until July 20 when it was removed from the website.

According to the report, the information contained in the file was limited, and no financial information or Social Security numbers were exposed. Affected plan members only had their name, diagnosis codes, provider information, date of birth, and information used for processing claims exposed, HIPAA Journal reported.

The investigators were not able to determine whether any unauthorized individuals accessed the file during the time it was on the website, and no reports have been received to date to suggest any protected health information has been misused.

A statement from the health insurer noted that the breach affects certain Independence Blue Cross members and members of its subsidiaries AmeriHealth HMO and AmeriHealth Insurance Co. of New Jersey. Fewer than 1 percent of total plan members were affected by the breach.

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