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The Health
Insurance Portability and Accountability Act (HIPAA) security standards became
law on 20 Feb 2003, and they are effective 21 Apr 2005.
What is HIPAA?
To give a too-simplified description, one of the features of the Health
Insurance Portability and Accountability Act -- HIPAA -- requires everyone in
the health care industry, from physicians to insurance companies, to protect the
data that patients entrust to them, ensuring that those data are only revealed
to persons and organizations with a legitimate need to know those data, and only
with the patient's prior permission. People and organizations affected by HIPAA
include the following:
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Providers:
hospitals, clinics, and anyone providing healthcare
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Payers:
insurance companies, HMOs and other health plans
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Other organizations
that do business with providers and payers must also comply with HIPAA
What is the
impact of HIPAA on Information Technology?
IT is a central function for most healthcare organizations and is more so with
HIPAA. IT must integrate adherence to HIPAA regulations into its "ordinary"
duties, ensuring a level of compliance, even if rote process is breached.
In addition,
there are specific new responsibilities for IT, including:
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The requirement of
recording access to Protected Health Information (PHI)
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Interacting more
frequently with legal organizations as legal works to ensure requirements are
sufficiently addressed
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Increasing security of
your systems
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Increasing security of
your network:
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Your LAN,
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Your access to the
Internet,
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Your firewall
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Intrusion detection
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Store records in a secure
area. Make sure only authorized employees have access to the area.
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Store paper records in a
room, cabinet, or other container that is locked when unattended.
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Ensure that storage
areas are protected against destruction or potential damage from physical
hazards, like fire or floods;
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Store electronic
customer information on a secure server that is accessible only with a
password -- or has other security protections -- and is kept in a
physically-secure area;
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Don't store sensitive
customer data on a machine with an Internet connection; and
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Maintain secure backup
media and keep archived data secure, for example, by storing off-line or in
a physically-secure area.
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Provide for secure data
transmission (with clear instructions and simple security tools) when you
collect or transmit customer information.
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If you collect health
information or other sensitive data, use a Secure Sockets Layer (SSL) or
other secure connection so that the information is encrypted in transit;
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If you collect
information directly from consumers, make secure transmission automatic.
Caution consumers against transmitting sensitive data, like account numbers,
via electronic mail; and
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If you must transmit
sensitive data by electronic mail, ensure that such messages are password
protected or encrypted so that only authorized employees have access.
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Dispose of customer
information in a secure manner.
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Hire or designate a
records retention manager to supervise the disposal of records containing
nonpublic personal information;
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Shred or recycle
customer information recorded on paper and store it in a secure area until a
recycling service that specializes in handling confidential recycling picks
it up;
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Erase all data when
disposing of computers, diskettes, magnetic tapes, hard drives or any other
electronic media that contain customer information (note that this is harder
than it seems -- technologies exist for recovering lost data -- these can be
turned to the recovery of data which you've deliberately
tried to destroy);
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Effectively destroy the
hardware;
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Promptly dispose of
outdated customer information; and
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Ensure all temporary
files created are fully encrypted and/or deleted.
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Use appropriate oversight
or audit procedures to detect the improper disclosure or theft of customer
information. For example, supplement each of your customer lists with at least
one entry (such as an account number or address) that you control, and monitor
use of this entry to detect all unauthorized contacts or charges.
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Maintain a close inventory
of your computers.
How can we
help you to with compliance?
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First, determine if there
are gaps currently in your:
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Security and privacy
policies and procedures
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The current state of IT
security
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Your IT security audit
capabilities
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Review appropriate
sections for compliance with HIPAA in areas such as
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IT technical security
mechanisms and capabilities
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Network/Internet/Dial-up
capabilities
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Physical access controls
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System access controls
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Data storage
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Design your:
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System and application
security configuration requirements
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Network
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Recommend internal
processes
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Implement the above
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Help you manage system
failures, including the prevention, detection, and response to attacks,
intrusions or other
system failures, including
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Help you develop a
written contingency plan to address any breaches of your physical,
administrative or technical safeguards;
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Develop a plan to
regularly obtain and install patches that resolve software security
vulnerabilities;
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Help you obtain and
install anti-virus software that updates automatically;
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Maintain up-to-date
firewalls, particularly if you use broadband Internet access or allow
employees to connect to your network from home or other off-site locations;
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Assist you in developing
and maintaining central management of security tools for your employees and
pass along to your designated personnel updates about any security risks or
breaches; and
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Double-check the
security of the system connecting via VPN from home (if the home system is
compromised, or is on a compromised home network, access to the secured
business network may be possible).
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