Are Healthcare CISOs Suffering from Cybersecurity Solution Fatigue? An Expert Probes Some of the Issues | Heather Landi | Healthcare Blogs Skip to content Skip to navigation

Are Healthcare CISOs Suffering from Cybersecurity Solution Fatigue? An Expert Probes Some of the Issues

July 15, 2016
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A recent Institute for Critical Infrastructure Technology report provided some intriguing thoughts about the pressure facing chief information security officers (CISOs) to keep their organizations secure and how they are combating information and vendor solution overload.

Given the often-reported high value of health data, healthcare organizations are facing ongoing and escalating cyber threats. In fact, media reports about ransomware attacks and data breaches against hospitals, health systems and medical practices seem to be occurring on a weekly basis at this point.

In a recent report, James Scott, a senior fellow at the Institute for Critical Infrastructure Technology (ICIT), a Washington, D.C.-based cybersecurity think tank, points out that a well-informed CISO can improve the engagement of the C-suite and improve the cyber posture of the organization.

“Due to the plague of APTs, malware, ransomware and other malicious initiatives by invisible adversaries, few C-level executive positions are as critical as the CISO,” Scott writes.

In the report, titled “CISO Solution Fatigue—Overcoming the Challenges of Cybersecurity Solution Overload,” Scott points out that, due to a variety of factors, CISOs combat information overload and vendor solution overload on a daily basis, and he emphasizes that CISOs need to learn how to prioritize and communicate strategically to be effective in their role.

While the report offers a cross-industry perspective of the CISO role and the challenge of vendor solution overload, the report author does spend moments focusing on healthcare organizations, specifically in a section detailing how CISOs can assess the return on investment of cybersecurity solutions.

The report provides an interesting perspective about the need for CISOs to ignore the hype surrounding “silver bullet” solutions in order find the most effective cybersecurity solutions and strategies for their particular organizations, but at the same time, the report author also highlights the part that the vendor community plays in this problem.

But first, the author offers some background on cybersecurity and the increasing importance of the CISO role. In the past five years, 54 percent of organizations have created the role of CISO within their organizational structure, according to the report.

“In many cases, CISOs operate under the unrealistic expectation that they should be able to prevent every breach with a finite budget. They are expected to have enough technical expertise to develop a strategy to protect the business and enough business acumen to convince the board to adopt that strategy because it aligns with the goals of the organization,” he writes. And, he asserts that modern CISOs tend to function more as Chief Information Risk Officers, managing the risk to data and technology.

According to the ICIT report, there is rapid burnout among CISOs, as the average turnover rate is 17 months. The report author credits this rapid burnout to a lack of understanding of the role and unhappiness in the position, as well as solution overload, “which results from the pressure to find comprehensive solutions and the overabundance of vendor solutions.”

Increased awareness of cybersecurity, and the increasing severity of cyber attacks, has driven investors to fund hundreds of new, innovative startups in the cybersecurity space, and many of these startups, Scott writes, “over-promise and under-deliver on their proposal by offering unreliable silver bullet solutions.”

The author also notes, “Aside from a rapid increase in venture funds, the vendor market has bloated due to the availability and affordability of cloud architecture. Software as a service (SaaS) delivery models have a very low barrier to entry. This allowed for cybersecurity startups that promised to solve every problem imaginable or who created new problems to solve.”

This portion of the report struck me, given that the healthcare industry is facing evolving data security threats. It seems, to me, that the role of CISOs to effectively protect an organization’s information assets and systems is daunting enough without adding new problems created by ineffective solutions.

Indeed, the author, Scott, calls out the vendor community when he writes, “Vendor attempts to offer silver bullet solutions undermine the community at large and poisons the vendor-customer relationship. The culture promoting these inadequate solutions distracts CISOs, technical personnel and solution developers from the risks and threats in the threat landscape and it distracts them from designing the right solutions to address the market needs.”

The author asserts that “reliable vendor solutions solve an actual market problem instead of a hypothetical or market-derived problem.”

Beyond calling out the vendor community for contributing to the “solution overload” problem, the ICIT report author also provides strategic recommendations for CISOs to overcome this obstacle.

The problem of “solution overload” can be overcome by altering the business model to value long-term stability over short-term potential gains. Vendor solutions need to be transparent, they need to support growth, and they need to offer layered security. Most importantly, the author writes, they need to perform as promised and address the needs of the organization.

In the report, the author’s strategic recommendations for CISOs as it relates to vendor solutions focus on three key areas—addressing organizational needs, communicating across the organization and return-on-investment (ROI). With regard to addressing organizational needs, the report touches on many solutions that most CISOs may already be aware of—data loss prevention solutions, application and system testing and penetration testing and the use of behavioral analytics systems, to name a few.

It’s been said that calculating the ROI for cybersecurity solutions can be difficult as cybersecurity doesn't contribute to an organization's bottom line. And, it also requires quantifying the financial impact on a hospital or health system’s reputation after a ransomware attack or breach.

In the report, the author offers strategic recommendations for calculating a cybersecurity solution’s ROI and uses a healthcare organization as an example. The ROI of security solutions can be equated to the fiscal component of the impact that the organization would assume if an adversary exploited the vulnerability that the solution addresses, the author writes.

“For example, assume that a hospital was attempting to procure a solution to prevent personnel from clicking on phishing emails because other hospitals had recently fallen victim to ransomware attacks through that vector. The CISO could begin to calculate the ROI by averaging the paid ransom demands or downtime costs (if the system was restored from backup) of other hospitals. The mission of many healthcare organizations is driven by their reputation; as a result, the CISO could calculate the reputational harm caused by a ransomware attack according to the publicity, charity, and other costs assumed to repair the organization’s reputation,” Scott writes.

Any impact on turnover or talent acquisition rates as a result of an attack and the associated costs should be included in the calculation, as well as any fines, breach notification costs, or other expenditures, the author notes.

And, the author contends that the risk assessment should also have predicted the likelihood of each cascading impact. “The probability of the impact should be multiplied by each associated outcome. For example, if an attack has a 10 percent likelihood in resulting in $10 million in reputational harm, then the product would be $1 million. The CISO should then take the aggregate of the probable potential impacts and multiply it by the probability that the organization will suffer an attack that the solution could prevent, within the lifetime of the solution. This number is the assumed cost that the organization faces if it does not adopt a solution,” Scott writes.

The report author sums up that the CISO can present the solution to the board according to the standard ROI model. “If the aggregate cost of the solution is equal to or lesser than the assumed impact, then the organization should adopt the solution because it has a positive or net zero ROI,” Scott writes. “Some organizations may even adopt negative ROI solutions if they are cautious, value public good more than the profit line, or if they expect aggressive changes in the threat landscape,” he notes.

The report concludes with statistics sourced from the Economist Intelligence Unit that indicates proactive CISO-led strategies can cut the success rate of cyber-breaches by more than 50 percent, hacking successes by 60 percent and ransomware infections by 47 percent.

The role of CISOs in healthcare organizations is more vital than ever, and ongoing discussions highlight that CISOS are facing a number of challenges, from all sides.

I found the issues and recommendations in the ICIT report to be insightful and thought-provoking, especialy with regard to communicating strategically across the organization and with the board. And, for all healthcare CISOs, the issues raised in the report are worth pondering as the need for optimal cyber defenses seems only to be intensifying.


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OCR Fines Providers for HIPAA Violations, Failure to Follow “Basic Security Requirements”

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) for a number of 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, OCR also fined a Colorado-based hospital, Pagosa Springs Medical Center, $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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