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At the Raleigh HIT Summit, Henry Ford Privacy Chief Harper Urges HIT Leaders to Action

October 20, 2017
by Mark Hagland
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Henry Ford’s Meredith Harper kicked off the Cybersecurity Forum in Raleigh with a compelling presentation

At the Raleigh HIT Summit, Henry Ford Privacy Chief Harper Urges HIT Leaders to Action

Henry Ford Health System chief privacy officer Meredith Harper kicked off the Cybersecurity Forum—day two of the Health IT Summit in Raleigh—with a compelling presentation on the journey of her organization into intensified IT security readiness

Henry Ford’s Meredith Harper kicked off the Cybersecurity Forum in Raleigh with a compelling presentation

In her keynote presentation to the audience at the Cybersecurity Forum, on day two of the Health IT Summit in Raleigh, sponsored by Healthcare Informatics, Meredith Harper, chief privacy officer at Henry Ford Health System (Detroit), urged audience members to move assertively to bake attention to patient data security and privacy into their organizations’ cultures. In an address entitled “Beauty and the Breaches: Results of an Attack at Henry Ford Health System,” Harper described four data breaches within the period of a few years that rocked her health system, but which also led to a transformation of Henry Ford’s culture around data, especially protected health information (PHI). And Harper’s presentation was followed by a lively discussion of CIOs’ responses to the WannaCry and Petya/NotPetya global cyberattacks this spring.

As the conference’s program agenda noted, “For Henry Ford Health System, cybersecurity has been a journey of continuous quality improvement and team collaboration.  Response plans ultimately netted beautiful results, as Henry Ford's Privacy and Security team ultimately expanded i's security scope following multiple high-risk scenarios over the course of the past seven years.”

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Speaking of the first breach, which involved the theft of a physician laptop with PHI on it, Harper said that it was becoming clear to her and her team that the Henry Ford organization faced certain ongoing set of vulnerabilities, despite having taken a series of actions to remediate the immediate situation. Referring to the executives in her organization, she said, “What I wanted them to see was that our culture was structured in such a way that this would happen again and again. What we realized,” she said, “was that the [data security] program was quite fragmented. We had security controls being put in place that were creating privacy problems.”

One of the most important points, Harper told her audience, is this: “The key to all of this is that your organization’s culture has to be a part of the discussion. The old adage that ‘culture will eat strategy for lunch every time’ is absolutely true,” she said.

Harper and her team made numerous important changes—among them, consolidating five previously disparate areas around information privacy, risk management, and network, and information security, together into a single unit under her direction, and tightening many processes. Among other things, Harper said, “We realized that we did not have a centralized investigative unit within my department, so I created it,” in order to achieve a level of investigative rigor needed and avert the leaking of information beyond appropriate team members. It gave us the ability to objectively investigate events without the inherent conflict with some line managers.


Meredith Harper

With regard to the physician who was at fault in the second breach, she told her audience, “We found that some levels of leadership were trying to cover for the physician in order to prevent his being disciplined, so we had to take that responsibility out of their matrix. Now, line managers support privacy  and security investigations, but they don’t lead any such investigations; any such situations have to come to our team for investigation.”

Further, the breach led to the creation of integrated privacy and security councils, as well as to a rapid-response team, called the “Code B Alert Team,” with “B” standing for “breach” in that context. “The rapid-response workgroup established to centrally respond to and manage all system data breaches,” Harper noted.

Nevertheless, a second breach occurred in 2011, when a pharmacy resident lost his unencrypted flash drive in the parking lot of a local McDonald’s restaurant. Given that that flash drive stored a spreadsheet of compiled information on 4,000 patients, Harper personally led a team of colleagues who combed through the lot physically, but who were unable to locate it. That incident led to an additional policy and operational change at Henry Ford: a new rule was instituted in which no flash drives would be allowed to be used in the health system that were not provided by and authorized by the organization, and fully encrypted.

“We reported this incident to the CEO, COO, and board again,” Harper noted. “And I looked back at the previous incident to see if we had some frequent flyers who had been part of the previous incident; and it turned out that we did. So the thing is that this is bigger than just containing an incident; our job is to restore patients’ faith in Henry Ford Health System.” As a result, she engaged the executives who led the calls to the impacted patients. That gave them the ability to understand all that goes into restoring the faith of an affected patient.

Meanwhile, Harper said, referring to an icon that was created in order to notify Henry Ford staff of any future breach, “We trained all 30,000 team members that anytime you see that big blue B, for a Code Breach Alert, you need to discuss the situation with your teams. We realized that we had not briefed the frontline staff in the clinics and hospitals, and realized that we needed to figure out how to help them comfort patients on the front line.”

Harper and her team also created a new program, called the iComply Program, in order to safeguard health system information. It includes the following phases:

>  Phase I targeted portable storage devices

>  Phase II targeted “culture” through educational modules

>  Phase III focused on reducing the organization’s “unsecured” printer footprint

>   Phase IV targeted the culture in order to reinforce HITECH and Omnibus federal privacy requirements

>  Phase V targeted BYOD (bring-your-own-device) mobile and broad mobile device management

>  Phase VI focused on vendor risk management

>  Phase VII involved a maturity assessment of the cybersecurity program

>  Phase VIII involved the creation of a video series entitled “Why iComply?”

Ø  Phase IX involved threat intelligence-sharing initiatives

The work around all this is ongoing, Harper told her audiences. “We continue to roll out iComply training—which is mandatory for all staff—across the organization.”

Meanwhile, a third breach within nine months occurred late in 2011. In that case, an iMac device was stolen that had information on 500 patients with HIV/AIDS on it. In that case, a staff member working in one of the health system’s research labs had propped open a door to one of the lab rooms so that she could run to the restroom and come back in without having to enter securely; during the time the chair was keeping the door open, someone came in and stole the laptop. “We moved through things pretty quickly and smoothly” she noted, having improved processes around breaches. What’s more, “technology would not have helped me in this instance,” as it was human misconduct that had led to that breach.

So that third incident, Harper told her audience, led to an intensification of efforts to continually educate all staff members. “We went directly to departments, and trained individuals with access to [sensitive data]. We did board training. We also found that we were getting a lot of general questions from patients and community members, often having nothing specifically to do with Henry Ford; so we took the opportunity to brand the conversations we were having them. We now do chat sessions with our patients, so that they can ask questions.” That initiative has been branded under the moniker “SecureSpeak.”

Still, the saga was not yet over even after that third incident. In 2013, a storage facility experienced a strange kind of theft. As Harper explained to her audience, there is silver embedded in old radiological films, silver that can be extracted and sold. In this incident, two workers who worked around a loading dock stole a batch of old films and attempted to themselves extract the silver from those films. The old-style films carry patient information directly on them, which meant that the PHI of more than 15,000 patients had been exposed.

That incident led to further refinements of the organization’s privacy and security initiative. Harper told her audience, “I had no idea at that point how many business associates we had. At that point, any manager could enter into a contract with a business associate; so we decided to bring that in-house, inside our team. And we made it so that only I and one other person could authorize the signing of an outside contract with a business associate. We have more than 1,500 business associates—that’s 1,500 opportunities for breaches. So we’ve centralized that, and we have a robust program. And we can do it in a more streamlined fashion,” she noted.

Meanwhile, a fifth incident occurred in 2014. In that instance, a Henry Ford physician went out and privately purchased an unencrypted flash drive, thus violating the organization’s iComply policy. He then added to the violation by lending that unencrypted flash drive to a fellow physician, who took the flash drive with him to an out-of-state conference, where he lost it. That flash drive contained the PHI of 2,336 patients. In that case, polices were already in place, and the offending physician was disciplined.

One of the key points of this narrative, Harper told her audience, is that “Repetition helps. We have to continuously educate and train our employees.”

In concluding her speech, Harper reemphasized the critical importance of developing a culture of data privacy and security, focusing on protecting patients and communities. She urged her audience to develop a full program of data privacy and security, and to constantly reinforce that program through continuous staff education, and rigorous application of policies and procedures.

After WannaCry

After Meredith Harper had completed her keynote presentation, that session was immediately followed by a panel discussion, focusing on CIOs’ responses to the WannaCry and Petya/NotPetya global cyberattacks earlier this year. Johannes (John) Boehme, chief information security officer at Wake Forest Baptist Health (Winston-Salem, N.C.) led a panel of two other hospital system healthcare IT leaders and one FBI agent. The two CIOs were Pamela Banchy, CIO of Western Reserve Hospital (Cuyahoga Falls, Oh.) and Colleen Ebel, CISO of UNC Healthcare; and they were joined by FBI supervisory special agent Jessica Nye, who is based in Raleigh.

Boehme led off the panel, entitled “Lessons Learned: Reviewing Incident Response to the WannaCry and Petya Global Outbreaks,” by asking the hospital panelists what actions they took in May, when the WannaCry virus exploded globally.

“We had a technical response team that notified me and the rest of us that morning, and made technical changes on our network, etc., doing an assessment across our network to find out where patches were absent,” Abel noted. “And then we opened up a command center that afternoon, which carried through to the next week. The state of security that you’re currently in, will influence what you do. The early response involved tightening up our current security controls, got into our antivirus protection software.”

Boehme offered that, at Wake Forest Baptist, “We have 2,500 servers, and found that 900 servers were missing that March patch” implicated in the WannaCry attack.

“We identified several that weren’t patched as well, so we applied those patches,” Banchy reported. “Meanwhile, others, we took off the network. We also did a complete inventory of our medical devices. We did have a war room or command center as well, but it was a weekend-long project to manage the situation. We did create an incident response protocol, and used some best practices along the way. We did have a highly controlled incident response area.”

“We have over 5,000 servers at UNC Healthcare, and the WannaCry incident led to a long response cycle,” Ebel said.

Meanwhile, in the regional FBI office, agent Nye said, “On that day, I received notification from our headquarters about the attack. And once we started getting that information, we started getting notifications from victims here in our AOR. We tried to start connecting the dots. Each victim would have a different experience. So we tried to quickly execute legal process, and go after the individuals” responsible for the attack. She noted that there are 56 FBI office and 358 satellite offices across the country, working with all types of business and professional organizations that might be affected by any such attack. What’s more, she said, it’s important to note that “It’s not just technology” that is very involved in responding to these situations, “it’s the personnel as well.”

“One of the biggest things is the executive awareness, and the financial investment,” Banchy emphasized, as the panel discussed the complexities and nuances of managing cyber risk.

“Do you work with HR to raise awareness?” Boehme asked his fellow panelists. “We have had situations where we’ve had to disable an account,” Ebel reported; and there have been situations in her organization when it’s been necessary to discipline staff members who have made very poor decisions.

“One of the things we’re moving toward is to absolutely lock down our production network, to where only medical center devices can be on the production network. That’s not gaining real favor with HR and employees, but it’s very necessary,” Boehme noted.


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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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