Utilize Systems Monitoring To Meet HIPAA Requirements

nurse computerAll systems monitoring should be configured to facilitate HIPPA compliance. However, the first step dictates that one deploys systems monitoring to all devices resident on the health care providers’ network. This often forgotten area of technology management needs illuminating to help bring some order and methodology to deploying activities that keep your medical enterprise fully HIPAA compliant.

HIPAA Security Rules specifically outline US national security standards to protect health data created, received, maintained or transmitted electronically, also known as electronic protected health information (ePHI). The HIPAA Security Rules are divided into 3 distinct categories and below is a summary of each.

  • Administrative Safeguards. This section of the HIPAA security requirements is focused upon establishing a risk analysis process, with periodic reviews, assigning security management responsibilities, formulating security policies and procedures and establishing appropriate workforce security training.
  • Physical Safeguards. This section of the HIPAA security requirements is focused upon securely controlling physical access: to data processing facilities, workstations and devices as well as physical media which contains PHI (personal health information).
  • Technical Safeguards. This section of the HIPAA security requirements is focused upon establishing specific technical security controls which aim to protect PHI via the following key aspects: data access control, data & access auditing, integrity and transmission security.

Below is a detailed description of each HIPAA related configuration item and the required guidance towards a HIPAA compliant configuration. As per the HIPAA requirements, for items listed as Addressable the entity must perform one of the 3 options: 1) Implement the required control as stated 2) Implement an alternative control which meets the intent of the original control 3) If implementing either, they must document the technical and or business constraint which prevents them from doing so. For items listed as “Required” the entity is required to implement this control as stated.

164.308(a)(3)(ii)(C) – Terminating Access

Addressable

Have you implemented procedures for terminating access to EPHI when an employee leaves your organization or as required by paragraph (a)(3)(ii)(B) of this section?

» Recommendation: Utilize the systems monitoring dashboard to remotely remove terminated employees from all in-scope EPHI related systems.

164.308(a)(5)(ii)(A) – Security Reminders

Addressable

Do you provide periodic information security reminders?

» Recommendation: Utilize systems monitoring to push periodic reminders to the in-scope workstations.

164.308(a)(5)(ii)(B) – Malicious Software

Addressable

Do you have policies and procedures for guarding against, detecting, and reporting malicious software?

» Recommendation: systems monitoring provides managed antivirus services that guard, detect and report against malicious software.

164.308(a)(5)(ii)(C) – Monitoring Login’s

Addressable

Do you have procedures for monitoring login attempts and reporting discrepancies?

» Recommendation: Utilizing the systems monitoring dashboard, develop procedures to periodically review audit logs and login attempts.

164.308(a)(5)(ii)(D) – Password Management

Addressable

Do you have procedures for creating, changing, and safeguarding passwords?

» Recommendation: Via the centralized management capabilities of the systems monitoring dashboard, develop procedures to create, change and safeguard passwords.

164.312(a)(2)(i) – User Identity

Required

Have you assigned a unique name and/or number for identifying and tracking user identity?

» Recommendation: systems monitoring requires each user ID to be unique and tracks activity according to such. Further, ensure there are no shared user accounts within the client environments you manage.

164.312(a)(2)(iii) – Inactive Sessions

Addressable

Have you implemented procedures that terminate an electronic session after a predetermined time of inactivity?

» Recommendation: systems monitoring automatically times out inactive user sessions.

164.312(a)(2)(iv) – Encrypting EPHI Data

Addressable

Have you implemented a mechanism to encrypt and decrypt EPHI?

» Recommendation: systems monitoring mail automatically and transparently encrypts all mail archives with secure AES 256bit encryption, thereby protecting any EPHI information potentially contained within the archive.

164.312(b)(2) – Audit Reporting

Required

Have you implemented Audit Controls, hardware, software, and/or procedural mechanisms that record and examine activity in information systems that contain or use EPHI?

» Recommendation: User audit reports are dynamically generated by default and can be accessed at any time via the systems monitoring dashboard. Develop procedures to periodically review and investigate any discrepancies.

164.312(d) – Authentication to EPHI Data

Required

Have you implemented Person or Entity Authentication procedures to verify that a person or entity seeking access EPHI is the one claimed?

» Recommendation: Consult with your client and determine the appropriate level of security. Upon such, implement strong password authentication & for further security, configure the systems monitoring dashboard to validate source IP addresses.

164.312(e)(2)(ii) – Encrypt EPHI Data in Transit

Addressable

Have you implemented a mechanism to encrypt EPHI whenever deemed appropriate?

» Recommendation: Configure systems monitoring mail to only transmit email traffic via IMAPS (IMAP over SSL) as this will securely encrypt and protect EPHI transmitted via email over the Internet.

Network Solutions Email Problems

Just received this update from my Exchange service provider about email problems with Network Solutions.

Service Advisory: [my provider] has discovered a possible issue with certain Network Solutions name servers. When looking up DNS information for domains hosted on Network Solutions or when querying Network Solutions name servers, we have seen intermittent time outs. This issue was discovered when customer reported bounce backs for people trying to send them mail. People sending to domains hosted on these servers may receive similar bounce backs. After some research, we found reports of similar issues by other companies (outside of [my provider]) and reports from Network Solutions stating that there may be a Denial of Service Attack (DDOS). We will monitor this issue and provide an update when the issue has been resolved by Network Solutions.

Such a shame that a company the size of Network Solutions allows this to happen. Top shelf Dynamic DNS provider Dyn, aka Dynamic Network Services, Inc and DNS provider OpenDNS figured out DNS long ago.

If it were my business depending on email, I would think seriously about deploying excellent hosting from Bluehost with DNS from OpenDNS and Dynamic DNS from Dynamic Network Services, Inc

Bluehost consistently makes it into the top hosting companies acclaimed “the best and brightest of the hosting world” by WordPress.

Family Internet Protection

Easily Block Adult Web Content From Your Family’s Internet

OpenDNS, one of the world’s top DNS providers, created FamilyShield, a free tool to help your family secure your Internet connection from Adult websites that are unsuitable for children, malware and virus websites and phishing websites that steal your personal information.

You can protect your family by following several very simple steps.

Navigate to the OpenDNS FamilyShield page and locate Setup FamilyShield. Click on “Set up FamilyShield”

 

fs

 

Enter your email address and click "Let’s Begin!" or, click "continue" to continue setup without signing up.

sufs

 

Select Router or Computer.

 

rc

 

Follow the simple instructions for your particular setup and you’re done!

I’ve used OpenDNS as a least cost/first deployment tool for years. If you want to monitor Internet usage as well as block and unblock websites, try the OpenDNS Basic product, also free, but it requires some additional configuration.Combined with a computer security product, your computers and laptops will run secure for years. And, your family will be protected from the dark side of the Internet.