Impact of Healthcare Regulations on the Data Center
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- Steven Manning
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1 Executive Report Impact of Healthcare Regulations on the Data Center
2 Impact of Healthcare Regulations The HIPAA and HITECH acts, along with the Affordable Care Act, are changing the face of the healthcare industry. These government reform efforts are aimed specifically at using technology to improve hospital efficiency and patient care. As a result, the government has established regulatory standards for everything from how electronic health record systems are used to how hospitals protect patient data and privacy. This technology-centered approach to healthcare represents a major shift from historical models. While medical technology has always been vital to care goals, information technology has been handled conservatively to avoid any risk. Over time, this approach has left many hospitals falling behind from a technological perspective, but the industry is now working to catch up. The influx of IT creates challenges in both operational and fiscal layers of hospitals, forcing them to deal with the emergence of new regulatory compliance, cost and big data-related issues. Individually, these issues are all problematic for hospitals. Facing each of them at once can be extremely daunting. This is creating an environment in which third-party help in the form of colocation and data center services is emerging as a key strategic enabler across the healthcare industry. The healthcare data deluge Hospitals have always dealt with large amounts of information, but the transition from paper to electronic records emphasizes not only the amount of data being dealt with, but the amount of information that should be used. With paper records systems in place, hospitals, physician offices and clinics maintained large quantities of files with individual patient data and only shared information when necessary. Healthcare reform is focused on not only improving how hospitals manage data, but how they use it. This means that more collaboration is necessary, data sharing is becoming critical and community care ideas are taking shape. This contributes to new challenges in a wide range of operational areas, including data protection, regulatory compliance and IT management. 2
3 Dealing with data protection Regulatory compliance and data protection are inherently linked, but there are facets of data protection that are vital regardless of what HIPAA standards promote, making a separate discussion of the two areas essential. From a purely operational standpoint, hospitals face a unique security challenge because they not only have to deal with usual data protection considerations, but they also face unique patient privacy challenges. On one hand, physicians need access to patient data to get the job done, while, on the other, not every doctor in a care facility can have the same access to data. Glenn Mamary, CIO of Hunterdon Healthcare System, says the health network had experienced this problem in the past, as a data storage model that was open to physicians led to some doctors looking at patient data that they did not have to view. 1 Therefore, Mamary developed a system that tightly protects who can access what data with sophisticated passwords, but features an override capability that physicians can use in the event of an emergency. These types of issues lead to major questions about where care providers should store data and how they should protect it. HIPAA guidelines provide the initial guidance that hospitals need in this area. Addressing HIPAA HIPAA regulations set a foundation upon which hospitals can build their data protection and privacy policies. However, HIPAA is not a handbook or even a set of best practices hospitals can follow. The problem is not that the guidelines themselves are flawed, but the industry is so diverse that HIPAA aims to establish a few broad common goals hospitals should strive to attain. The standard is not designed, in most areas, to tell care providers how they should achieve the end results. Hospitals have to evaluate their own operational and technological capabilities and navigate the regulatory climate to achieve success in data protection. For example, HIPAA regulations mandate certain types of patient health information be accessible at all times to ensure continuity of care. This means while most businesses can focus on IT disaster recovery during an outage, hospitals have to first ensure they have business continuity plans in place before moving on to recovering normal functionality. How hospitals accomplish this is up to them. This is one area where colocation can help by keeping data accessible in a remote location. 3
4 The other challenge when dealing with HIPAA is it does not only apply to hospitals and care providers, it also impacts any business partners or organizations handling patient data. Healthcare industry companies are responsible for ensuring they only work with business partners that can meet HIPAA requirements. These factors are combining to put a significant burden on hospitals because IT functionality plays a central role in supporting HIPAA compliance. Furthermore, HIPAA and the HITECH Act deal primarily with protecting patient data and keeping it private; attesting for meaningful use, which is the central theme of healthcare reform, adds another level of challenges. Meaningful use attestation While HIPAA is one of the most frequently discussed elements of healthcare reform, meaningful use is the central point upon which HIPAA revolves. Meaningful use standards are clear and actionable care goals set forth by the government to ensure consistently high-quality care around the country. Guidelines range from using technology to enable data sharing and fuel collaboration to asking patients specific questions during consultation to better evaluate their general health. HIPAA is in place to ensure that patient data is protected while the reform efforts included in meaningful use are put into place. At its core, meaningful use standards are focused on encouraging hospitals, physician offices and clinics to not only deploy EHR systems, but to allow increased IT functionality to permeate operations to such an extent that it leads to care improvements. They are about effectively using EHR infrastructure. This requires innovation on three levels - internally, within a care network, and within the larger community. Internally, effective EHR deployment in hospitals hinges on being able to share data between labs and other departments and patient care areas. This ensures physicians have the information they need when they need it, but also it is accurate and includes any supplemental details that can improve care. This process, in and of itself, is heavily dependent on robust server and storage systems that can handle high-density operations and function reliably. 4
5 Meaningful use also encourages better data sharing and collaboration within a health network. A hospital physician specializing in a certain type of care can use EHRs more meaningfully when he or she has access to the same patient data as the primary care physician. The process of sharing data across EHR systems hinges on advanced IT capabilities that not only enable this type of functionality, but also allow for effective security and privacy measures to be put into place. These initial forays into big data expand exponentially when getting into community health. Championed by accountable care organizations, but essential in the industry as a whole, community health processes involve analyzing patient data corresponding to individuals within a town, county, state or even country and using that information to identify individuals who may be at risk. While community care could prove vital in supporting healthcare reform efforts, it also puts a considerable burden on the data center. Any operational practice involving big data or similar types of processes hinges on aligning the storage and server setups to work effectively in conjunction with each other. The performance challenges, however, are only part of the problem. Protecting patient data is also a vital consideration. Data center protection is becoming a critical issue in healthcare and it is a challenge that involves a combination of access control, cyber security, uptime and facility security considerations. These are all things hospitals have not had to deal with to this degree in the past and may not be able to afford to handle now. Considering the cost side of meaningful use Implementing the IT infrastructure needed to achieve even the first stage of meaningful use is incredibly expensive, and that only addresses initial EHR implementation and internal integration. Expanding to the external and community care goals that could drive long-term gains for hospitals requires even more hardware. Government reform efforts are built to make up for this problem, as hospitals that can attest for meaningful use can obtain stimulus funding. Over time, organizations that do not attest for meaningful use will face repercussions in the form of adjustments to Medicare and Medicaid reimbursements. 5
6 While the funds available for achieving meaningful use provide some help for hospitals, they are dwindling quickly and are proving to be insufficient for covering the cost of more robust technological deployments. This is leading to the emergence of major roadblocks across the industry as many hospitals are trying to comply with government reform goals but are in a financial position that limits innovation. As a result, many CIOs are beginning to seek more creative ways to deploy and manage the IT infrastructure needed to support operations. Meaningful use is only one side of the cost equation. The amount of funding needed to support attestation is significant, but so is the potential loss for hospitals unable to comply with meaningful use or HIPAA regulations. Dealing with regulatory costs Hospitals failing to attest for meaningful use have to deal with Medicare and Medicaid reimbursement cuts, which could severely impact the revenues of many care centers. Furthermore, unexpected costs caused by non-compliance with HIPAA standards can also create problems. The costs of any type of outage or data loss incident, while substantial, are almost impossible to clearly identify. This difficulty is because outages involve several variable conditions. A data breach of any sort can lead to fines, reputational damages, fees associated with credit card tracking for those affected by the event and a variety of other conditions. As a result, hospitals have to invest heavily in security and data protection to avoid HIPAA-related issues and ensure patient data privacy. Dealing with complexity and cost The myriad of factors that come together in HIPAA, the HITECH Act, the Affordable Care Act and meaningful use attestation are pushing healthcare into a new era of dependence on IT functionality. Furthermore, these problems are being exacerbated by the growing importance of cloud computing, mobility and other emerging technologies that are taking hold in the sector. 2 In response, healthcare CIOs have to find ways to improve functionality substantially while also reducing costs to a meaningful extent. This is an area where colocation and similar data center services pay major dividends. 6
7 Using colocation to reduce cost and complexity One of the core gains associated with colocation is the elimination of capital costs needed to build a new data center. While this benefit is clear, healthcare organizations benefit even more from the holistic vision of a well-designed colocation strategy. When companies use colocation effectively, they gain access to more robust and sophisticated data center resources than they can usually manage on their own. However, they do this without giving up control of their IT systems. When working with a hosting provider that can operate within HIPAA and HITECH regulations, this positions hospitals to simplify the process of complying to regulatory standards by making data center systems more reliable, accessible and redundant. Colocation provides a foundation for the high-density server and storage environments needed to deal with the data-related challenges facing hospitals. Colocation also helps hospitals by providing them with facility and management improvements. A colocation data center designed for healthcare can offer robust network and physical security, as well as access control measures within the data center, to ensure regulatory compliance. At the same time, power and network redundancy combined with the flexibility offered by colocation providers makes the service model much more reliable than premise-based data centers. Using colocation to enable scalability Another key need for hospitals is scalability. As EHR functionality grows and hospitals deal with more IT systems, they need a data center that can adapt to shifting operational requirements. The leasing model used by colocation vendors provides flexibility from a cost standpoint. Facility design within colocation centers allows for scalability from an IT perspective. Using colocation for security and reliability Security and reliability also play major roles in healthcare, especially as regulatory guidelines specifically address such issues. Protecting data is an incredibly important consideration for hospitals because the costs of a data breach can escalate quickly. Colocation improves security and privacy on multiple levels. On a physical layer, colocation facilities provide access control features that tightly regulate who can 7
8 enter the building, who can access the data center floor, who can maintain equipment and who can actually view server environments. This security not only keeps data protected from physical theft, it also provides the privacy-related nuances needed to ensure that people only view the information they are authorized to see. Secure networks, which play a major part in colocation services, add a key layer of logical protection to patient data. Reliability is not an area where hospitals can afford to take risks. Lives can be lost if IT systems go down and patient data becomes unavailable. Most colocation facilities feature redundant power supplies and network systems to ensure constant availability. Furthermore, providers can house client data in multiple facilities, ensuring that data is available even if there is a problem at one of the data centers. This enables hospital CIOs to be confident that the data clinical staff members will be present at all times. While the IT innovation needed to support HIPAA, the HITECH Act, the Affordable Care Act and meaningful use standards is daunting, HIPAA-compliant colocation services offer the cost efficiency and performance needed to help hospitals comply with government reform efforts, contributing to the greatest gain of all - more lives saved through better care. 8
9 About CyrusOne With 24 colocation facilities across the United States, Europe, and Asia, CyrusOne helps many of the world s largest global businesses including over 100 of the Fortune 1000 companies and 9 of the Fortune 20 and companies of all sizes take advantage of the latest data center technology and realize top operational efficiencies through: Flexible design Scalable, customized data center solutions that are engineered with Massively Modular data center technology to align with your business needs Personalized service High touch customer service delivered by data center experts Full transparency Full transparency in communication, management, and service delivery High reliability Excellent availability using state of the art technology backed by 100% service level agreements (SLA) About the Author Scott Brueggeman oversees the management of CyrusOne s global marketing, product development, inside sales, and corporate communications including branding, demand creation, and public relations. His 20 years of marketing and sales experience includes Fortune 50 firms, as well as smaller high-growth companies. Prior to CyrusOne, he spent several years with running marketing at CoreLink, a data center hosting and managed services company, as well as Chief Marketing Officer at PEAK6 Investments, an international financial services firm. Prior to that he was SVP Marketing for Socrates, VP Marketing for CareerBuilder, and also held leadership positions at AT&T and PepsiCo. Brueggeman serves on several advisory boards. References 1.Schetman, Joel. Healthcare CIOs Must Walk Fine Line Between Doctor Access and Patient Privacy. The Wall Street Journal. N.p., 15 Aug Web. 03 Dec < 2.Versel, Neil. Healthcare IT: How Reform Is Giving CIOs A More Strategic Role in Delivering Patient Care. CIO. N.p., 23 Sept Web. 03 Dec < Patient_Care>. 9
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