Cloud Computing in a HIPAA- Compliant World. NRTRC Telemedicine Conference Dean Oswald March 25, 2014
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1 Cloud Computing in a HIPAA- Compliant World NRTRC Telemedicine Conference Dean Oswald March 25, 2014
2 Agenda Cloud overview Infrastructure-as-Service overview HIPAA-compliant IaaS Risk cost speed tradeoffs Responsibility matrix for HIPAA requirements New technologies Customer Examples Recap 2
3 Why is it called the cloud? Network Cloud Originally network shorthand for: Magic happens in here and we don t know/care how it works. 3
4 Evolution toward the cloud 4
5 IT decisions balance conflicting goals Reliability DR Compliance Security Must Have Nice to Have Ease of Use Risk Features CapEx OpEx Staff Cost Speed Deployment Upgrades Scalability 5
6 Cloud computing is like a miracle drug Higher overall reliability Lower overall risk Risk Features Adequate features, growing Applications delivered via web browser Reduces CapEx Lower & usage based OpEx Reduces staff Cost Speed Faster deployment Automatic upgrades Huge scalability 6
7 Cloud computing service models 7
8 What is Infrastructure-as-a-Service (IaaS)? 8
9 Infrastructure-as-a-Service benefits An excellent option for healthcare organizations that are: Facing the expense of a technology or hardware refresh Ready to implement EMR and EHR solutions that require complex environments Short-staffed due to changing needs or loss of experienced IT professionals Desiring a Disaster Recovery environment outside their own region Concerned about ephi security or other compliance issues (HIPAAcompliant providers) Seeking a more predictable cost structure 9
10 HIPAA-compliant IaaS Added requirements based on HIPAA and/or HITECH-Act regulations External auditor assesses organizational, administrative, physical and technical controls Validation of compliance with policies and procedures by review of logs, configuration, records and interview of personnel Evaluation and validation of architecture, including interviews of personnel responsible for design and implementation, for Technical Safeguards Validation of physical controls deployed in the environment Privacy Rule requires Business Associate agreement 10
11 A common control design assessment model 11
12 Example requirements: Administrative Safeguards Standard Requirement ES Client Both Security Management Process HIPAA (a)(1)(i) Workforce Security HIPAA (a)(3)(i) Information Access Management HIPAA (a)(4)(i) Security Awareness and Training HIPAA (a)(5)(i) Risk Analysis and Management Sanction Policy Information System Activity Review Authorization and/or Supervision Workforce Clearance Procedures Termination Procedures Isolating Healthcare Clearinghouse Function N/A N/A N/A Access Authorization Access Establishment and Modification Security Reminders Protection from Malicious Software Log-in Monitoring Password Management 12
13 Example requirements: Physical Security Standard Requirement ES Client Both Facility Access Controls HIPAA (a)(1) Device and Media Controls HIPAA (d)(1) Contingency Operations Facility Security Plans Access Control and Validation Procedures Maintenance Records Disposal Media Re-use Accountability Data Backup and Storage 13
14 Example requirements: Technical Safeguards Access Control HIPAA (a)(1) Integrity HIPAA (c)(1) Standard Requirement ES Client Both Unique User Identification Emergency Access Procedure Automatic Logoff Encryption and Decryption Mechanism to Authenticate Electronic Protected Health Information Transmission Security HIPAA (e)(1) Integrity Controls Encryption 14
15 RTO decision drives your options 16
16 New technologies ease compliance SSD with flash storage Always on encryption Meets data-at-rest requirement Protects against drive theft or loss in transit or maintenance A combination of software-based and ASIC-accelerated encryption for no performance loss 17
17 Customer example #1 Oregon-based Hospital Large skilled internal IT staff Significant assets already in place Hardware refresh provided opportunity to improve DR Solution Primary infrastructure in EasyStreet colocation 9-cabinet cage Redundant/diverse connectivity DR infrastructure located at hospital site Data replication/dr playbook managed by hospital IT 18
18 Customer example #2 Arizona-based healthcare provider New green-field clinical information system Complicated modern application Extremely high availability/performance required Solution HOT/HOT Disaster Recovery Solution (RPO 1 hour, RTO 4 hours) Identical dedicated private clouds in Beaverton and Phoenix Multiple replication techniques used Database / storage / hypervisor based DR playbook jointly developed by customer and EasyStreet 19
19 Recap The cloud delivered as Infrastructure-as-a-Service is an excellent option for healthcare organizations Ensure you re in compliance with your IaaS provider Have them sign a Business Associate agreement Request a Responsibility Matrix Your IaaS provider can help balance the risk/cost/speed or hot/warm/cold requirements that are right for your organization New technologies overcome risk/cost/speed limitations Inline encrypted storage 20
20 Thank you! Call
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