The Second National HIPAA Summit
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1 HIPAA Security Regulations: Documentation and Procedures The Second National HIPAA Summit Healthcare Computing Strategies, Inc. John Parmigiani Practice Director, Compliance Programs Tom Walsh, CISSP Practice Manager, Enterprise Security This document is provided for educational purposes, as is without any warranty of any kind, either expressed or implied.
2 Presentation Outline Many organizations are searching for guidance on how to implement HIPAA Security Standards. This presentation offers some ideas and the policies, procedures and documentation required by HIPAA. Part 1 Overview What is HIPAA... 1 Administration Simplification (Diagram) Security Goals Observations HIPAA is More About Change than Technology (Diagram) Part 2 What is Required... 2 Policies, Procedures, Forms & Memos (Diagram) Security Policies Administrative Procedures (Table) Physical Safeguards (Table) Technical Security (Table) Transmission Security (Table) Elements of a Security Program (Diagram & Table)... 5 Part 3 Getting Started... 6 Roles and Responsibilities Security Planning Policies and Procedures Workstations Media Controls (CIA) Part 4 Implementation... 8 Certification of Systems Training, Education and Awareness (TEA) Configuration Management Incident Report and Handling Part 5 Changing the Culture... 9 Today s Situation Resource Considerations Part 6 Conclusion , Healthcare Computing Strategies, Inc. i
3 Implementation of the HIPAA Security Rule Documentation and Procedures 1. Overview What is HIPAA? HIPAA The Health Insurance Portability and Accountability Act of 1996 (HIPAA) Public Law All titles have been implemented except: Title II, Subtitle F - Administrative Simplification Title I: Insurance Portability Title II: Administrative Simplification Title III: Medical Savings and Tax Deduction Title IV: Group Health Plan Provisions Title V: Revenue Offset Provisions Title II: Administrative Simplification EDI Security Privacy Security Requirements Administrative Physical Technical Technical Procedures Safeguards Services Mechanisms 12 Requirements 6 Requirements 5 Requirements (Data at rest) 1 Requirement (with 7 Features) (Data in transit) 2001, Healthcare Computing Strategies, Inc. 1
4 Is security a business enabler or an expense? Security Goals Confidentiality Integrity Availability Observations Cannot attempt to impose monolithic solutions Continuous development process Two Year Requirement - Opportunity for assessment Need for a Best Practices document HIPAA is More About Change, than Technology Culture Trillion dollar cottage industry Caring is sharing Highly proprietary Operations New Policies & Procedures Process redesign Official guidelines Technology Medical Highly sophisticated Essential Information Heterogeneous By necessity 2. What is Required High Level Policies Procedures Low Level Forms & Memo Detail 2001, Healthcare Computing Strategies, Inc. 2
5 Security Policies Administrative Physical Technical Formal mechanism for processing records Information access control Sanction Policy Assigned security responsibility Media controls Physical access controls Workstation use Authorization control Administrative Procedures Policy Proc. Form Memo Certification Chain of trust partner agreement Contingency plan Disaster Recovery Emergency Mode Access Procedures Formal mechanism for processing records Release of Information Confidentiality Agreements Information access control Request for UserID & Password Role-Based Authorization Internal audit Personnel security Clearances (Background Checks) Security configuration management Change Control Inventory (Property Pass) Security Testing Security incident procedures Security management process Security Policy (Overall) Risk Analysis & Management Sanction Policy Termination procedures Exit Interview Checklist Training Attendance Sheet, Test, etc. 2001, Healthcare Computing Strategies, Inc. 3
6 Required Policies, Procedures, and Documents (Continued) Physical Safeguards Policy Proc. Form Memo Assigned security responsibility Media controls Accountability (Liability Agreements) Backups Disposal Physical access controls Escort procedures Visitor sign-in log sheet Policy/guideline on workstation use Secure workstation location Security awareness training Technical Security Policy Proc. Form Memo Access control Procedure for Emergency Access Audit controls Logs Authorization control Request for UserID and System Access Data authentication Entity authentication Transmission Security Policy Proc. Form Memo Communications/network controls (Access controls, Alarm, Audit trail, Encryption, Entity authentication, Event reporting, Integrity controls, Message authentication.) Optional: Software Use Modem Use Internet and Usage Classification of Information (Assignment of Data Ownership) 2001, Healthcare Computing Strategies, Inc. 4
7 Elements of a Security Program Secure your enterprise and compliance will follow. Steve Hunt, GIGA 12/99 Four Cycle Process: Manage Assess Prevent Detect Manage 1. Roles and Responsibilities (Planning and hiring) 2. Security Planning 3. Policy and Procedures 4. Security Management Assess 5. Risk Assessment (Organizing) 6. PC Workstation Security (Laptop & Portable) 7. Systems Security (Servers & Mainframes) 8. Communication Security (Network) 9. Software (Operating System & Application) 10. Media Controls & Information Security The real threat lies not necessarily in the distant chance of the interception of patient information in transmission, but the storage and management of the information once it is received. Encrypting patient information during transmission is due diligence. But once the information is received and decrypted, what level of protection is applied to the information? Prevent 11. Certification of Systems (Directing) 12. Training, Education & Awareness 13. Physical & Personnel Security 14. Access Control (Physical, Logical, & Remote) 15. Configuration Management 16. Contingency & Disaster Recovery Detect 17. Audit Trails (Controlling) 18. Audit Controls & Alarms 19. Incident Reporting & Handling 20. Program Review (Internal Audit) 2001, Healthcare Computing Strategies, Inc. 5
8 3. Getting Started Roles and Responsibilities Assign Security Responsibility Information Security Manager / Officer Privacy Officer Assignments Responsibilities include: 1) The use of security measures 2) The conduct of personnel Establish a What attributes do you think a good security manager needs? Security Planning Brief management and leadership on HIPAA and its impacts Establish a Determine resources required: Budgets, staff, equipment, etc. Policies and Procedures Review and update existing policies and procedures Create new policies and procedures What are the fallacies of policy? 2001, Healthcare Computing Strategies, Inc. 6
9 Workstations (Then and Now ) Hardware Software Location Support Malicious Code Misuse & Abuse Mainframes & Terminals Custom Designed Centralized Few; Highly Skilled Few Rare Guideline on Workstation Use (Includes laptops) Documented instructions/procedures delineating the proper functions to be performed, the manner in which those functions are to be performed, and the physical attributes of the surroundings, of a specific computer terminal site or type of site, dependant upon the sensitivity of the information accessed from that site. Part of Physical safeguards to guard data integrity, confidentiality, and availability on the matrix. Information protection (Log off) File storage and deletion Disposal procedures Monitor position Donut Strike Media Controls (CIA) Controlled access to media (E: Patient information stored on a server) Accountability Liability Agreements Data backup, storage and Protecting Patient Information Printed Faxed Stored Paper and electronic media Transmitted CIA = Confidentiality, Integrity, & Availability 2001, Healthcare Computing Strategies, Inc. 7
10 4. Implementation Certification of Systems What? The technical evaluation performed as part of, and in support of, the accreditation process that establishes the extent to which a particular computer system or network design and implementation meet a pre-specified set of security requirements. This evaluation may be performed internally or by an external-accrediting agency. Part of administrative procedures to guard data integrity, confidentiality, and availability. Training, Education and Awareness (TEA) Training = Education = Awareness = The goal of TEA Changing Behaviors Configuration Management What is the difference? Documentation Change control Security Testing (After significant changes to system) Anti-virus updates Are there procedures for the implementation of software patches and security advisories? Incident Report and Handling Can associates identify an unauthorized use of patient information? Do associates know how to report security incidents? Will associates report an incident? Do those investigating security incidents know how to preserve evidence? 2001, Healthcare Computing Strategies, Inc. 8
11 5. Changing the Culture Today s Situation Limited resources for security Privacy is not a market differentiator Most believe Up until HIPAA, few incentives for security How long does it take to change an organization s culture? Resource Considerations Time - 26 months from final rule posting Money - Cost of compliance unknown People - Skilled staff in EDI and security Vendors - Hardware and software 6. Conclusion Determine what are the policies, procedures, and forms your organization will use to prove compliance. Get started now by building a good security program and HIPAA compliance will follow. Everyone is still struggling along - No organization can claim to be compliant because the final rules are not published. Thanks for attending! It is our hope that this presentation served your needs. We welcome your feedback. If we can be of help to you in the future, please contact us at: jcparmigiani@hcs-is.com Voice: (410) trwalsh@hcs-is.com Voice: (913) , Healthcare Computing Strategies, Inc. 9
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