Cybersecurity: It’s a healthcare risk issue

Wannacry may be the best thing that has happened to the healthcare industry in a long time. It brought to light just how terrible a job the industry does in protecting patients from identity theft.  That's what it means to lose a patient's protected health information or PHI. PHI is now a currency on the black market.  It is worth over a 100 times the value of a credit card record.  If you're a covered entity (healthcare plan, healthcare clearing house, or healthcare provider) or a business associate ...

Missing the HIPAA Target – Part 4

In my first blog of this series, I stated that the intent of HIPAA was not to make you an expert on regulations, but to guide you to be risk management proficient, which is the ability to recognize threats and risks to your practice and manage them to eliminate or minimize their impact.  The next installment was accountability; taking ownership and delivering verifiable results.  This was followed by the importance of training.  What is the next? Well, you need to know how to identify risks and th ...

Care Disruption – The Ultimate Security Risk

We in the cybersecurity and HIPAA compliance communities talk a lot about breaches and fines and total costs of breach remediation - yadda, yadda, yadda. All non-trivial realities to be sure, but when the WannaCry ransomware attack paralyzed hospitals and physician practices and pharmacies and surgery centers around the globe, I was thinking about the members of the care team. Elective surgeries can be postponed and lots of routine wellness services, such as eye exams and hearing tests and school physic ...

HHS OCR: PHI Security is your top priority

If you haven't noticed, cybersecurity is a major issue in the world, politically, economically, and even personally.  No one wants their identity stolen.  No business wants to deal with customer (patient) retaliation caused from losing their personal health information, whether it's boycotting, bad press, negative social media or a class action lawsuit. In general the U.S. government is taking action to help protect small businesses by requesting a new standard cybersecurity guide be written by the Nat ...

Missing the Target of HIPAA – Part 3

If you haven't read my previous two blogs on this topic I encourage you to do so.  The first blog stresses the importance of being risk management proficient over being a HIPAA “expert”. The second blog deals with being accountable in your work actions, which means not only are you responsible for your actions, but your actions can be independently verified.  These two “factors” can go a long way to protecting your organization from the risks of a breach and from substantial penalties and fine ...

Cybersecurity: Have you hardened your systems?

We perform HIPAA Risk Assessments (Security Risk Analysis) for very small practices to large healthcare organizations, plus business associates that include software, big data, and marketing companies.  We know the focus of the assessment needs to be security; therefore, we run an industry standard (NIST based) scan checking computers for HIPAA compliance.  (NIST stands for National Institute of Standards and Technology) Our findings show that the average covered entity is about 15% compliant and the ...

HIMSS17 – OCR’s Expectations for HIPAA Compliance

Lessons Learned at HIMSS17 The Office for Civil Rights (OCR) made it clear at HIMSS17 - it’s time for the healthcare industry to take action NOW.  Here are the top messages we heard across multiple presentations by HHS (OCR, CMS), FDA, FTC, law firms, and cyber security firms. The following were made very clear to attendees.  Please note, these are not all from HHS, some were heard multiple times from various sources.  The point is, learn and take action. Ignorance of the HIPAA law is no e ...

HIPAA: Reducing Your Liabilities

As we perform more Security Risk Analyses, (we actually do privacy and security risk assessments), we continue to hear doctors, executives, and office managers consider HIPAA an onerous burden.  They tend to see it as painful compliance overhead and a total waste of time.  But, that is a very dangerous view of HIPAA compliance. HIPAA compliance is actually attempting to provide a guide for the healthcare industry to operate their business so they REDUCE LIABILITIES.  It reduces the likelihood of h ...

Knock, Knock – We’re here to perform an onsite HIPAA audit.

  Welcome to 2017.  If you haven't heard, the Health and Human Services Office of Civil Rights (OCR) will perform several hundred on-site HIPAA audits this year. The possibility of being selected is highly unlikely, but if you are one of the "lucky" covered entities that is audited you had better be ready - with all your ducks in a row. Current HIPAA training is only one duck, you need at least four more.  So, prepare to go duck hunting and get them in order sooner rather than later. Ther ...

Avoid the HIPAA Wall of Shame

There are several things a healthcare covered entity or business associate needs to do to avoid HIPAA fines and the possibility of being listed on the wall of shame, but the immediate need is to perform a thorough risk assessment. And that usually means having a third party perform a credible risk assessment that includes privacy, security and technology assessments. Unless your organization has conducted a thorough risk assessment in the last 12 months and taken action to address issues, you're playing ...

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