1 For more information on how to build a HIPAA-compliant wireless network with Lutrum, please contact us today!
2 This publication describes the implications of HIPAA (the Health Insurance Portability and Accountability Act of 1996) on a wireless LAN solution, and highlights how Meraki can be used to implement a HIPAA-compliant network infrastructure. The target audience of this publication is healthcare IT administrators who are responsible for the design and implementation of a wireless network.
3 Copyright 2009 Meraki, Inc. All rights reserved. Trademarks Meraki is a registered trademark of Meraki, Inc Alabama St. San Francisco, California Phone: Fax:
5 HIPAA (the Health Insurance Portability and Accountability Act of 1996) calls for the establishment of national standards for technology involved in health care transactions in order to protect the health information of individuals. HIPAA compliance applies to any healthcare facility that exchanges patient health information. HIPAA s objective is to ensure that health information remains private and secure. Achieving this objective involves not only implementing policies and procedures for personnel, workflows, and inventory, but also evaluating physical assets to ensure that every piece of equipment will play its part in upholding HIPAA compliance. A wireless LAN is no exception. Wireless hardware, such as access points (APs) that are installed around a facility, must demonstrate HIPAA compliance. Similarly, wireless software must support the security and management features that the facility requires to enforce HIPAA compliance. This whitepaper summarizes the key tenets of HIPAA that are relevant to a wireless LAN, describes the wireless features that can satisfy these requirements, and shows how Meraki can be used to build a HIPAA-compliant wireless LAN.
6 To understand how HIPAA impacts a wireless LAN, many layers of legislative text need to be peeled back. Enacted by the U.S. Congress in 1996, HIPAA comes in two parts: Title I and Title II. Title II of HIPAA strives to reduce health care fraud and abuse. Subtitle F of Title II is known as the Administrative Simplification provisions, which requires the establishment of national standards for electronic health care transactions, along with national identifiers for various health care entities (e.g., providers, health insurance plans, etc.). Administrative Simplification defines 5 rules, one of which is the Security Rule, which describes the requirements that relate specifically to electronic protected health information. The Security Rule identifies 3 types of security safeguards required for compliance: 1. Administrative safeguards define personnel and management processes to train employees who come into contact with private health information, detect privacy violations, and handle those violations. 2. Physical safeguards are policies and procedures that govern the addition and removal of hardware, access to equipment, etc. 3. Technical safeguards are guidelines for data encryption, data corroboration, and audit logging. These 3 safeguards translate into specific requirements for a wireless LAN. The requirements are not described in HIPAA, however. As administrative law, HIPAA defines the policy that must be implemented; the actual implementation (i.e., codification ) of this policy is left to the Code of Federal Regulations (CFR). CFR Title 45, Part 164 is called Security and Privacy. Subpart C of this section is called Security Standards for the Protection of Electronic Protected Health Information. This text was written as a response to HIPAA, and it deconstructs HIPAA s 3 security safeguards (administrative, physical, and technical) into actionable requirements that a wireless LAN must satisfy. Specifically, each safeguard consists of a list of standards, and each standard may consist of one or more implementation specifications, which are designated as either required or addressable (i.e., implement as applicable). The implementation specifications that are relevant to a wireless LAN are highlighted below and are described in the following sections. (Each section begins by listing the implementation specifications addressed in parentheses.) Because the technical safeguards define the greatest number of implementation specifications that impact the wireless LAN, this section is addressed first. Many of the other implementation specifications are outside the scope of a wireless LAN because either they pertain to overarching security policies and processes (e.g., workforce clearance procedure) that are not technology-specific,
7 or they pertain to a different technology area that is not related to wireless connectivity (e.g., protection from malicious software).
8 All but one of the implementation specifications for the technical safeguards should be addressed by a wireless LAN. Because of the relevance of this section, all implementation specifications are addressed for completeness. (Access Control: Unique User Identification) This implementation specification requires a system that passes private health information to control access on a per user basis. Within a wireless LAN, each user must be assigned a unique username and strong password, and must use these credentials to access the wireless network. The wireless LAN should also be able to track these users in a log of user activity (e.g., successful and failed authentication attempts, association and disassociation times, etc.). Finally, the wireless LAN should be able to provide different levels of access to different groups of users. For instance, guests should obtain Internet-only connectivity from the wireless network, without any ability to reach private health information. Employees, on the other hand, should be able to access all parts of the network. A wireless LAN can provide this access control by broadcasting different SSIDs (the wireless networks that a client device detects), allowing an administrator to configure different access control settings on each SSID. (Access Control: Emergency Access Procedure) An emergency access procedure allows personnel to access private health information during an emergency. A wireless LAN may assist with this requirement by providing LAN access to wireless users, even if connectivity to the public Internet is down. In this way, personnel can wirelessly access health information that may be stored on local file shares during an emergency. This always up capability is revisited as part of the emergency mode operation plan, which is specified as part of the administrative safeguards. (Access Control: Automatic Logoff ) Automatic logoff terminates a user s session after a predetermined time of inactivity. This feature is most relevant to the application that provides the user with access to private health information. A wireless LAN may perform its own automatic logoff to disconnect a user after a preconfigured period of time.
9 (Access Control: Encryption and Decryption, Integrity: Mechanism to Authenticate Electronic Protected Health Information, Person or Entity Authentication, Transmission Security: Integrity Controls, Transmission Security: Encryption) The objective of all of these implementation specifications is to provide authentication to ensure that information is accessed by a trusted or approved user, integrity to ensure that information is not altered in transit, and confidentiality to prevent a man in the middle from stealing information as it is transmitted. All 3 attributes are intrinsically connected; as such, they should be satisfied simultaneously and comprehensively, rather than piecemeal. Currently, best practices call for 802.1x (also known as WPA2-Enterprise), which uses public key infrastructure (PKI) to authenticate endpoints, provide integrity through digitally signed data packets, and negotiate cipher keys for the strongest encryption possible (i.e., 256-bit AES). Older authentication and encryption methods have their downsides. WPA2 with a pre-shared key (WPA2-PSK, also called WPA2-Personal) provides sufficient encryption with a suitably long and complex key, but pre-shared keys can easily be shared with other (potentially unauthorized) users. An acceptable variation is to use WPA2- PSK with a splash page that requires a user to enter username/password credentials. Under no circumstances should WEP be used in an organization concerned about HIPAA. Not only does WEP suffer from the same ease of key sharing among users as WPA2-PSK, but with today s processor speeds, it is also far too easy to crack a WEP key. The bottom line: Use (1) 802.1x or (2) WPA2- PSK with username/password splash page login. (Audit Controls) Audit controls enable an administrator to monitor user activity on systems that access private health information. A wireless LAN should provide a log of userlevel events, such as associations, authentications, and bandwidth usage. The log should be descriptive enough to allow an administrator to pursue the appropriate remediation steps(e.g., block the device, contact the user, etc.).
10 The administrative safeguards are mostly concerned with the management procedures and processes that govern how private health information is handled. A few of the implementation specifications defined as part of administrative safeguards have implications on the wireless LAN. (Security Awareness and Training: Log-in Monitoring) Log-in monitoring calls for record-keeping of the administrators who access any systems that transmit or store private health information. For a wireless LAN, such a record is important for forensic analysis. For instance, an administrator might inadvertently disable encryption on the wireless network, which could allow an eavesdropper to capture private health information over the air. A record of administrator logins (both successful and unsuccessful) and their configuration changes allows an organization to determine who committed the configuration change to disable wireless encryption, and when the configuration change took place, which identifies the exposure time of the misconfiguration. (Security Awareness and Training: Password Management) Password management requires procedures for creating, changing, and safeguarding administrative passwords. Every wireless LAN should be able to provide this capability in a scalable and centralized way. Rather than replicating administrative accounts on individual APs (as is the case with autonomous or fat APs), a centralized management solution should be sought, which manages and stores administrative accounts to access all APs across the entire network. (Security Incident Procedures: Response and Reporting) A mechanism is needed to alert administrators to suspected or known security incidents, to mitigate the incidents as much as possible, and to document the incidents and their outcomes for future analysis. A wireless LAN should provide as much information to administrators as possible through these alerts. Security alerts should report on security incidents that pertain to administrators, (e.g., excessive administrative login attempts), wireless users (e.g., excessive user login attempts), and wireless devices (e.g., rogue AP detection). Management alerts should report on any events that are actionable by administrators for instance, if an AP goes down.
11 (Contingency Plan: Data Backup Plan, Contingency Plan: Disaster Recovery Plan) These implementation specifications call for procedures to back up data and recover data after the emergency is over. For a wireless LAN, the most critical data typically reside in the management interface and may consist of configuration, administrative accounts, and user accounts. (Larger organizations would likely store and manage user accounts on a dedicated authentication server, such as Active Directory. This server would have to be backed up separately.) A controller-based wireless LAN typically provides an administrator with the ability to export a configuration file off of the controller. This configuration file can be uploaded back to the controller in order to restore settings. Alternatively, a cloud-managed wireless LAN should provide this data backup to an organization transparently through redundant systems in multiple, geographically distributed data centers. (Contingency Plan: Emergency Mode Operation Plan) Systems should be able to tolerate failures and outages gracefully during emergencies. Systems should remain operational as much as possible so that private health information can still be accessed. The need for a wireless LAN to continue operating when the public Internet is unavailable was discussed as part of technical safeguards. Here, the architectural and administrative implications of providing an always up wireless LAN are considered. At a high level, a wireless LAN should eliminate single points of failure. A common limitation of controller-based wireless LANs is that the controller must be reachable by the APs in order for the wireless network to remain operational. As such, administrators often find themselves deploying redundant standby controllers that take over when the primary controllers go down a deployment with significant cost and management implications. More preferable is an architecture that eliminates the controller as a single point of failure. A cloudmanaged wireless LAN allows the APs to remain operational (i.e., providing wireless access to users), even when connectivity to the cloud-based management interface is unavailable. As such, a cloud-managed architecture has no single points of failure.
12 The implementation specifications for physical safeguards are generally outside the scope of the wireless LAN. They relate mostly to controlling access to facilities and equipment in particular, those that store private health information. Two implementation specifications should be addressed. (Facility Access Controls: Facility Security Plan) The facility security plan describes the need to secure physical property and equipment from unauthorized physical access, tampering, and theft. In a wireless LAN, the APs are the components that are most prone to tampering due to their placement nearest to the users they serve. APs should be secured by locks (e.g., Kensington locks and mounting brackets) and positioned out of reach of users. Example mounting locations include high on walls, on ceiling, or inside the plenum (if the APs are plenum-rated). For a controller-based wireless LAN, the controller is the most expensive piece of hardware in the network. As such, it also needs to be secured, typically inside an access-restricted data center. Besides being a sitting target for theft and tampering, the controller is also a sitting target for network security breaches. Many security vulnerabilities have been identified with wireless LAN controllers over the years. Gaining access to a controller can compromise not just the wireless LAN, but even the entire network. Organizations that want to minimize their security exposure, both physical and logical, should consider a cloud-based wireless LAN, which eliminates the need for a controller altogether. (Device and Media Controls: Media Re-use) If a system stores private health information, there needs to be a way to clear that information before the system is reused for a different purpose. For a wireless LAN, the implication is simple: Ideally, no component of the wireless LAN should ever store user data.
13 Meraki satisfies all of HIPAA s wireless LAN implementation specifications. The requirements described earlier are now revisited to show how they are satisfied by Meraki. Requirement Unique User Identification Emergency Access Automatic Logoff Authentication, Integrity, and Encryption Audit Controls How Meraki Satisfies Meraki APs can broadcast up to 16 SSIDs simultaneously, each with its own security, network, and access control settings. For authentication, Meraki supports 802.1x and username/password login via a splash page. User credentials can be validated against either a customer-premise authentication server (such as Active Directory, LDAP, or RADIUS) or a Meraki-hosted authentication server. Through the Meraki Cloud Controller, an administrator can obtain a complete log of the users and devices that have connected to the Meraki wireless network, and view a history of bandwidth usage. The Meraki wireless LAN stays up, even if connectivity to the Meraki Cloud Controller becomes unavailable. Users can continue accessing LAN resources without interruption. Meraki provides flexible access policies, including the ability to log off users after a preconfigured period of time. Meraki supports WPA/WPA2-Enterprise (802.1x) with strong 256-bit AES encryption and WPA/WPA2-Personal (pre-shared key). Communication between the APs and the Meraki Cloud Controller is conducted over a secure SSL connection. An administrator can see all events related to wireless users on the Meraki network, including wireless associations/disassociations, authentication attempts, DHCP requests/renewals, and traffic initiation.
14 Requirement Log-in Monitoring Password Management Response and Reporting Data Backup and Recovery Emergency Mode Operation How Meraki Satisfies The Meraki Cloud Controller provides a complete log of administrative activity, including logins and configuration changes. In addition, different privilege levels (read-only and full read-write access) can be specified for different administrators. An administrator can create, modify, and delete administrator accounts through the Meraki Cloud Controller. A single account can be used to configure and monitor thousands of Meraki APs in a single network. A whole suite of security and management alerts can be communicated to administrators, including rogue AP detection and AP outages. Remote hands tools enable an administrator to troubleshoot an AP in a remote office without requiring any on-site resources. The Meraki Cloud Controller is hosted in multiple, geographically distributed data centers for high availability and reliability. The Meraki wireless LAN does not require any hardwarebased wireless LAN controllers, reducing physical and network security risk. Requirement Facility Security Plan Media re-use How Meraki Satisfies Meraki s n indoor APs are plenum-rated. Each comes with a security screw, Kensington lock hard point, and a padlock hard point. No user traffic is ever stored on a Meraki AP, nor does user traffic flow back to the Meraki Cloud Controller. For more information on how to build a HIPAA-compliant wireless network with Meraki, please contact an authorized Meraki partner. Or, you can contact Meraki directly at or
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