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Special Report: As IT Security Concerns Intensify, CIOs and CISOs See a New World

September 15, 2016
by Mark Hagland
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Industry experts see the list of IT security threats lengthening in healthcare

Industry experts are agreed: most of the issues that have risen to the top of the list when it comes to IT security threats facing U.S. patient care organizations in the past year or so haven’t really changed; they’ve only intensified.

To illustrate just how difficult and confounding things have become, Healthcare Informatics reported in June that, according to a June 26 article posted by the news site DeepDotWeb, “A hacker claims to have 655,000 patient records allegedly obtained by hacking into three separate healthcare databases, and is attempting to sell those patient records on the dark web marketplace. According to the DeepDotWeb article… the hacker communicated with the site’s writers via an encrypted conversation,” Healthcare Informatics Assistant Editor Heather Landi noted in an article published online on June 28. “While it has not been verified whether any healthcare organizations have actually been hacked, the hacker provided the media site with images of the database hack from their internal network. The screenshot photos show healthcare databases that expose sensitive patient information, including full names, addresses, date of birth, social security numbers and other information…” What’s more, “The hacker claims to have three separate healthcare databases from healthcare organizations in Farmington, Missouri, an undisclosed location in Central/Midwest U.S. and one in Georgia, and is allegedly selling the databases on a dark web marketplace.”

Such developments can only add to the accelerating level of concern among healthcare IT leaders and industry experts, as ransomware, all types of malware, and other threats are posing a constant menace to patient care organizations and to patient data. Recent surveys on data security continue to affirm what everyone in U.S. healthcare already knows—patient care organizations are under assault as never before from cyber-criminals, with cyber-criminality having risen in the past few years to an unprecedented level of crescendo, overshadowing all other types of data and IT security threats.

Those with the title of chief information security officer (CISO) in patient care organizations are well aware of the scope of the threats.  For example, when asked what the top data and IT security threats he faces are, Howard Haile, vice president and CISO at SCL Health, a multi-hospital health system based in Denver, says, “For me, the two things we’ve been dealing with the most are outsider threats attacking our users, gaining access to our network and data; and the other is the risks related to old legacy systems, such as medical devices that reside on the network. And there are a lot of them; there are way too many legacy devices and other systems dependent on older systems.”

Howard Haile


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And Fernando Blanco Dopazo, vice president and CISO at the 60-hospital CHRISTUS Health, based in Irving, Tex., says, “I see three major issues right now. The first one is reducing risks of external threats. That involves the basic blocking and tackling of protecting the organization. This is something that in my opinion the healthcare industry hasn’t done well in the past, and is something we’re working on now. The second thing is related to compliance. We have different initiatives we need to comply with, including HIPAA, and including external audits, which are increasing. And the third one is what we call building the resilient organization. It’s not ‘if’ you get compromised, but when. So it’s preparing for incidents. That’s a very important third pillar that we’re working on.”

Fernando Blanco Dopazo

Industry experts concur. Certainly, ransomware is "one of the top issues,” says John Peterson, a manager in The Chartis Group, a Chicago-based consulting firm. “And in terms of what CIOs and CISOs should be concerned about, the core topic isn't the data breach; it’s about securing their environment,” says the Albany, N.Y.-based Peterson. “Because it’s not if they’ll experience a data breach, it’s when,” he says, echoing Blanco’s statement. “You think of huge companies like Sony Pictures or Target, that shouldn’t be breached, but are. There are internal threats, and external threats. And Experian, the credit agency, puts out a report periodically; and in a recent report, the Experian people identified that 81 percent of all security events in 2014 were caused by employee negligence,” most commonly loss of user credentials—ID and passwords.

The issues are definitely multi-dimensional, and “They break down into different categories,” adds Mac McMillan, CEO of the Austin, Tex.-based CynergisTek consulting firm. “One of the biggest concerns I hear CIOs express is that they’re deathly afraid of that cyberattack that either ends up being a massive breach of millions of records, or takes their hospital offline, where they are publicly embarrassed because they can’t provide services,” McMillan says. “I’ve had CIOs say to me, I’ve worked really hard to build my career as a CIO; I don’t want a cyber-attack to destroy my career. So I think it’s that bit cyber-attack that they all know is possible, and they don’t know that they’re ready for.”

Levels of Vulnerability

Given all these threats, what are the levels of vulnerability that CIOs, CISOs and other healthcare IT leaders need to consider right now?

“When we talk about a data protection perspective, there are two issues intrinsically involved,” says CynergisTek’s McMillan. “Number one, do I have the right architecture and technology in my environment to help protect me? And number two, am I capable of doing the things that I need to do, to make my environment more resilient? When you know that 90 percent of the breaches that have occurred, have occurred not because of some sophisticated attack, but because of something that wasn’t fixed, like a patch that wasn’t done, you realize that you have to ask, why is it that we’re not patching as frequently as we need to or not hardening systems as much as we should?”

Mac McMillan

In other words, McMillan says, those responsible for data security in patient care organizations are “off-tempo: they’ve got so many demands on them. It’s like, when you’re really busy in your life, how often do you clean your house? And you walk in one way and the sun is shining on your coffee table, and you say, oh, shoot, I need to dust. And we all know we need to dust regularly. And that’s the same thing with the network: we all know that we need to patch, need to harden, need to test, on a regular basis. But when we’re so busy, it’s hard to do that.”

Related to all this is the “very big issue” of resources, McMillan continues. “It’s not just the resources to maintain the proper hygiene in the environment, but the fact that this industry is desperate for qualitied IT security people. That’s an issue they’re facing. So when you break that protection piece down, there are two issues: one is having the time and resources to manage the environment; and the other is making the investment in the security technologies today. Do we have intrusion detection systems, advanced malware detection? The list goes on and on. But the point is, have we invested in the technologies that we need today to fight the cyber battle from a protection perspective” Our architecture in our IT system needs to be as resilient as it possibly can be. In short,” he says, “we must make investment in technology, and in the resources and time to handle the hygiene issue.”

There is another element here, though, that is often overlooked, McMillan says. “The next phase of this challenge is really the detection phase, knowing when I’m being attacked: do I have the right level of visibility into what’s going on in my environment? And a lot of CIOs acknowledge that they don’t know what’s going on in their environment. Someone gets in there and is in there for three months, six months, nine months, before they’re detected. And a lot of our hospitals are now beginning to wake up and realize that they don’t have the capability or the expertise, or the people, to really monitor what’s going on their environment in a proactive fashion.”

Auditing, Backup Seen as Very Important

The Chartis Group’s Peterson agrees that auditing of data patterns, and behavioral monitoring, can be helpful. “Absolutely they can be,” he says. “I’m working with an organization where we’re implementing this, in terms of behavioral patterns in the EMR, and we produced a report, and created alerts per the criteria. It also turned out to be a very valuable tool for doing not only regular auditing, but also for any investigations that may come up.” Meanwhile, regular backup remains extremely important, too. In that regard, Peterson says, “As far as backup is concerned, there are different ways to do it. Organizations can do backups daily. Sometimes, they’re incremental backups, sometimes full backups, depending on how much data they have, and how much storage they have. And where they put those backups—sometimes in ransomware situations, it turns out that the backup files have become encrypted as well. So it’s best practice not to keep your backup files on the same network as your live files. And whether that’s in cloud. The key thing is not to keep that in the same location. And also with regard to the credentials of who has access to this. You don’t want a lot of users have access to all that data; it has to be limited.”

In the end, what everyone interviewed for this article agrees on is that the data security threats are only going to continue to intensify, and that CIOs, CISOs and other healthcare IT leaders can never expect a letup. It’s a new world now, says George McCulloch, executive vice president for membership and professional development at the Ann Arbor, Mich.-based College of Healthcare Information Management Executives (CHIME), and “What keeps everyone awake at night is the constant threats and intrusions that occur.” Patient care organizations “are getting hammered thousands and thousands of times a day,” he emphasizes. “It’s continuous, it’s worldwide, and the threats keep on changing. And so it’s just a constant drumbeat of, OK, something else is going to happen today, somebody else is after me. That’s what worries everybody is, I could be the next victim. And what haven’t I protected that I’ve could protect? It’s like being at war every hour of the day; there’s no break.”


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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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