Cyber Security, Data Breach, Education, HIPAA / HITECH Enforcement, Meaningful Use, News Events, Risk Analysis/Risk Management, Tip of the Week

Challenges of Meaningful Use

Challenges of Meaningful Use

Meaningful Use (MU) is the adoption of a certified Electronic Health Record (EHR) technology with a focus on improving quality, safety, efficiency, and reducing health disparities in the clinical/hospital setting. The idea is to increase patient engagement to improve care coordination while maintaining the privacy and security of the patient’s Protected Health Information (PHI).

According to Milan (July 27, 2015) “After a day spent hearing from health IT experts about information blocking practices, Republican Sen. Lamar Alexander, chair of the Senate Health, Education, Labor & Pensions Committee, said Thursday afternoon that he’s asked HHS to consider a delay of Stage 3 meaningful use”. The Department of Health and Human Services (HHS) is the U.S. government’s main agency for enhancing and protecting the health and well-being of all Americans.

Here are some quotes from Senator Lamar Alexander:

“Let’s not impose on physicians and hospitals a system that doesn’t work…”

“We want something physicians buy into, rather than something they dread…”

It is important to update and improve our current way of keeping health records as well as a more appropriate way to share health information with other providers. The quality of the EHR tool becomes the most desirable trait it seems. Remembering HIPAA where the importance of assessing all of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of all Protected Health Information (PHI) is required. However, each medical provider is unique in their operational environment with their own set of variables and must be factored in to the equation.

Another important piece of information according to McCarthy (July 22, 2015):

“Stage 3 of meaningful use for EHR implementation requires providers to send electronic summaries for 50 percent of patients they refer to others, receive summaries for 40 percent of patients that are referred to them and reconcile past patient data with current reports for 80 percent of such patients. If other providers do not send electronic summaries, however, the provider who was supposed to receive them will fail to meet the second and third requirements.”

Probst (2014) mentioned from an interview that Intermountain Healthcare is Stage 2 Certified in 2014 but will not be attesting at this time.

The Agency for Healthcare Research and Quality (AHRQ, March 26, 2015) provided some research data on barriers to meeting the stage 3 criteria for Meaningful Use:

  • Lack of provider and practice staff time – 69%
  • Complexity of required workflow changes – 68%
  • Difficulty with electronic exchange of information – 65%
  • Direct Financial Costs – 54%
  • EHR design and functions do not easily support care coordination – 51%

Readiness to meet criteria results:

  • Only 11% of those who participated in the research are able to meet all of the criteria

AHRQ’s mission is to “bring about evidence to improve health care quality and safety, increase accessibility, equitability and affordability within the HHS and other partners. Their objective is to ensure that the evidence is understood and employed.

Stages of MU

For more information on Stages of Meaningful Use Click the link above

These are only some views on the subject of Meaningful Use, but there are many standards, policies, ideas that are available from other organizations that might be helpful.

Our work here at RISC Management has enabled us to view firsthand the privacy and security challenges of Meaningful Use, and of course HIPAA and HITECH. These are significant challenges that the Providers must meet, but they are reasonable and attainable.

OFFICIAL RISC Logo

For more information on Risk Analysis Click the link above

References

Agency for Healthcare Research and Quality. (March 26, 2015). Informing stage 3 meaningful use requirements through evidence: Webinar. Retrieved from https://www.youtube.com/watch?v=nQrMKcq0VAM

McCarthy, Jack. (July 22, 2015). Stage 3 meaningful use ignores market realities. Retrieved from http://www.healthcareitnews.com/news/brookings-meaningful-use-stage-3-ignores-market-realities

Meaningful Use. (2015) Definition. Retrieved from http://www.healthit.gov/providers-professionals/meaningful-use-definition-objectives

Miliard, Mike. (July 23, 2015). Senate suggests stage 3 MU delay. Retrieved from http://www.healthcareitnews.com/news/senate-call-stage-3-mu-delay?mkt_tok=3RkMMJWWfF9wsRohuKTPZKXonjHpfsX57e8uUKOylMI%2F0ER3fOvrPUfGjI4GRMVkI%2BSLDwEYGJlv6SgFQ7LHMbpszbgPUhM%3D

Probst (2014). CIO on MU stage 2: Certified but not attesting. Retrieved from http://bcove.me/kt82385m

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Business Continuity, Cyber Security, Data Breach, Disaster Recovery, Education, HIPAA / HITECH Enforcement, Risk Analysis/Risk Management, Social Media, Tip of the Week, Vulnerability Testing & Management

Get Involved and Do Your Part to Make the Internet Safer

Promote the National Cyber Security Awareness Month (NCSAM). Get involved and do your part! This is a job for everyone, make an effort to care! The theme for this year is “Our Shared Responsibility”. NCSAM will be observed in October, but make it part of your practice to start today.

Top 5 Reported Cyber Scams

 

 

Staff can do

 

For more information on keeping current on cybersecurity, vulnerabilities, data loss prevention, managing risks, and workforce members training, Contact RISC Management and Consulting, LLC at 800.648.4358 or visit www.RISCsecurity.com

To learn more about Cyber Security visit: https://www.staysafeonline.org/ncsam/landing-page/

 

Cyber Security, Data Breach, Education, News Events, Risk Analysis/Risk Management

Breach Update

There have been multiple breaches in the news recently, headlined by the hack of the Office of Personnel Management (OPM) that exposed the information of potentially 18 million people at last tally. It was also recently announced that Blue Shield of California had also experienced a minor breach that affected 843 individuals through a coding error on one of their secure web sites. Within the past month, other notorious events included breach alerts from password manager LastPass and the Houston Astros, a professional MLB club.

While the cause may be different (or still unknown) for each of these events, they can all serve one purpose for any organization: take security seriously. Potential risks exist internally and externally for any organization that maintains or processes important and valuable data such as electronic Protected Health Information (ePHI). With the black market value of health records on the rise, it is imperative for all organizations to make efforts to ensure the confidentiality, integrity, and appropriate availability of sensitive data.

Straightforward steps towards building or maintaining a successful security program always start with a Risk Analysis. Without quantifying the potential risks to your organization, it is difficult to make informed decisions, especially when trying to purchase the right tools or delegate your workforce efforts. The next step is generally to analyze your policies and procedures. These documents state your organizations intent to comply with applicable regulations or frameworks. Maintaining up-to-date procedures is important for ensuring continuity in all of your regular processes and saves valuable time. Once each of the above has been addressed, it is then time to train your workforce. This accomplishes a number of goals including increasing the effectiveness of security controls, improving workforce efficiency, and protecting the organization in the event of a breach or other security incident.

These are just the first steps towards building a security program; there are a number of other technical, administrative, and physical controls that must be implemented to avoid breaches and comply with the standards and regulations of your industry. However, without these building blocks for long-term success, it might not be farfetched to find your organization on the OCR’s Wall of Shame.

To find help with a third-party Risk Analysis, policies and procedures, training, or any other security controls, contact RISC Management & Consulting today!

Cyber Security, Data Breach, News Events

Cyberattacks Against United States Targets, the White House, and a Critical Presidential Declaration!

The White House has been in the news over the past two weeks in reports from USA Today, CNN, NBC News, and many more sources.  Officials informed NBC News (Mitchell, 2015 April) that it is believed the Russians accessed the system through State Department computers which contained private unpublished schedule of President Obama. While attribution usually takes weeks or months for the FBI’s Cyber Division to determine and publish, the sources of the attacks are less important than the objective. The objective is similar across all of these attacks; to retrieve classified information. According to former FBI official Shawn Henry and the president and CSO of CrowdStrike Services cyber-attacks occur because countries such as China and Russia have the need to look at U.S. polices, how policies are created, new initiatives that are under consideration, basically anything that these foreign countries can get that will provide them with some advantage at the next level of trade talks and collect intelligence against the US for personal gains.

Healthcare organizations need to understand the criticality, reasoning, and determination for these attacks as well. When VIPs such as political or military leaders are seen or treated by their facility, or by a facility they are affiliated or networked with, their systems, networks, and data become a high priority target for foreign threat actors. Healthcare organizations often fail to realize how important their health information data repositories are for reasons entirely Unrelated to identity theft or medical billing fraud. Basic healthcare information about a head of state, a state department official involved in a negotiations process, senior leadership in the military or a congressional committee is incredibly important to both Nation-State actors and Terrorist organizations. Healthcare providers have no idea that cyber-bullets are flying by their ears in this electronic war!

On April 1st, 2015, President Barack Obama sent out an Executive Order titled “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled activities”.  Here’s a short excerpt from the Executive Order:

Obama quote April 1 2015

Only a few months ago on January 13th, President Obama announced a legislative National Data Breach Notification standard and miscellaneous cybersecurity legislative proposals and efforts.  The Executive Order should provide the U.S. government the tools needed to combat the expanding malicious cyber activities.  The Executive Order enables the Treasury Department along with the Attorney General and the Secretary of State to impose sanctions on the unlawful actions created by hackers. The goal would be to freeze targets’ assets when operating in the U.S. financial system and prohibiting them from having transaction with American companies.

Both Public and Government sectors must pay immediate and substantial attention to this existing and evolving threat!

References

Henry.S. (2014, November 17). Cyber attacks hit State department email, web. Retrieved from http://www.cnn.com/videos/bestoftv/2014/11/17/lead-intv-henry-state-department-hacking.cnn

Hollywood Reporter. (2015, April 1). Obama creates federal sanctions to deal with cyber attacks. Retrieved from https://www.youtube.com/watch?v=dNFdUphnU18

Mitchell, A.(2015, April). Russia hacked White House last year, U.S. officials says. Retrieved from http://www.nbcnews.com/news/us-news/russia-hacked-white-house-last-year-u-s-officials-say-n337521

Whitehouse.gov. (2015, April 1). The White House: Executive order. Retrieved from https://www.whitehouse.gov/the-press-office/2015/04/01/executive-order-blocking-property-certain-persons-engaging-significant-m

Cyber Security, Data Breach, Disaster Recovery, Education, Tip of the Week

Phishing Lifecycle

Phishing is a form of social engineering and works like a con game. A phishing attack is performed using email, a malicious website, or even a direct phone call to the victim. The many purposes of phishing include collecting personal information, gaining access to corporate information, gaining access to corporate information systems, installing malware, or even holding data hostage by changing local encryption keys! The information that is accessed or copied by the attacker is used for gaining access to your accounts such as your financial accounts, committing identity theft, gaining access to corporate networks and systems, changing credentials, or even holding your data hostage.

Quote Mitnick

Social Engineering can be a positive or negative attack using human interactions to obtain information about your organization. The person attacking could potentially be someone hired by the company to locate gaps in their security or, more likely, maliciously by those wanting to hurt you or your organization. During the attack, the person will seem unassuming, or even helpful, and be able to blend in with the employees. Through this process, he/she/they are able to ask questions, retrieve data, take photos for evidence if hired by the company or infiltrate the office or department.

Lure hook catchThe attacker might send a false e-mail often that look surprisingly legitimate, and may seem valid. However, it is important to view the URL in the address field which can tell you if the page you have been directed to is not valid. The email might come from a credit card company requesting you to respond and might often come from other types of organizations such as charities during a natural disaster, holidays, etc. Some phishing attacks involve a phone call directly to the target, where the attacker often claims to be another employee, perhaps calling from the I.T. Helpdesk.

According to the U.S. CERT and IRS remaining alert and knowing the tricks can assist you in avoiding or repelling these malicious attacks. Here are their explanation (2015, January 30):

Spot common elements of the phishing lifecycle

  1. A Lure: enticing email content.
    • Example 1 of actual phishing email – see below
    • Example 2 of actual phishing email – see below
  2. A Hook: an email-based exploit.
    • Email with embedded malicious content that is executed as a side effect of opening the email
    • Email with malicious attachments that are activated as a side effect of opening an attachment
    • Email with “clickable” URLs: the body of the email includes a link, which displays as a recognized, legitimate website, though the actual URL redirects the user to malicious content
  3. A Catch: a transaction conducted by an actor following a successful attempt.
    • Unexplainable charges
    • Unexplainable password changes

Sample of Phishing Email from IRSIRS does not initiate taxpayer communications via email

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Again, don’t be a victim and watch for any unexplainable changes to your financial accounts. If you think there’s a slight chance that your sensitive information was breached, change your passwords immediately. If you use the same passwords in multiple areas, it is important to change each one of those accounts as well. Remember not to use that particular password again in the future.

If you receive a phone call that you suspect of being a phishing attack, tell the caller that you need to call them back at the number you know to be the person or department they represent. For example, if the caller claims to be from the I.T. Helpdesk, tell them you are calling them back at the officially listed number (Never at the number the caller gives you), and hang up. Using a corporate directory, a known number, or a number in your contact list on your corporate-owned phone, call that department back and verify the communication to you, and their request. Never connect to a remote access service such as GoToMyPC, or setup a remote service request through Microsoft Windows when receiving a phone call that you did not initiate.

References

Mitnick. K.(2000, March 2). Frontline: The testimony of an ex-hacker. Retrieved from http://www.pbs.org/wgbh/pages/frontline/shows/hackers/whoare/testimony.html

Phishing. (2015). TechTerms.com. Retrieved from http://techterms.com/definition/phishing

U.S. Computer Emergency Readiness Team. (2013). Security tip (ST04-014): Avoiding social engineering and phishing attacks. Retrieved from https://www.us-cert.gov/ncas/tips/ST04-014

U.S. Computer Emergency Readiness Team. (2015, January 30). Security Tip(ST15-001): IRS and US-CERT Caution users. Retrieved from https://www.us-cert.gov/ncas/tips/ST15-001