Remote-access Guide

hipaa hitrust detect remote access

by Prof. Aryanna Littel II Published 2 years ago Updated 2 years ago
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Is working remotely a HIPAA compliance risk?

While there are several advantages of working remotely, there’s a monstrous risk for those that are obligated to comply with HIPAA: keeping clients’ protected health information (PHI) safe. Not convinced it’s a big deal?

What does the HITECH Act mean for HIPAA?

The HITECH Act also expanded HIPAA's already broad “business associates” definition, which includes: health information exchange organizations, e-gateways handling ePHI and subcontractors that create, receive, maintain, or transmit PHI on behalf of a business associate23.

Is telecommuting a HIPAA compliance risk?

This can save a company as much as $11,000 annually per telecommuting worker. While there are several advantages of working remotely, there’s a monstrous risk for those that are obligated to comply with HIPAA: keeping clients’ protected health information (PHI) safe.

Are you prepared for HIPAA enforcement audits?

Preparing for HIPAA enforcement audits starts with due diligence for business associates – such as Microsoft Office 365 with Teams implementation. Microsoft has undergone its own HIPAA Security and Privacy compliance assessment following their responsibilities as a business associate10.

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Is Remote Desktop Connection HIPAA compliant?

Windows Remote Desktop Protocol can be used for remote access, but RDP is not HIPAA compliant by default. Without additional safeguards, RDP fails to satisfy several provisions of the HIPAA Security Rule.

What is the difference between HIPAA and Hitrust?

HIPAA is a U.S. law that includes a set of safeguards that covered entities and business associates must follow to protect health information. The HITRUST CSF is a certifiable security and privacy framework with a list of prescriptive controls/requirements that can be used to demonstrate HIPAA compliance.

Does Hitrust include HIPAA?

HITRUST has supported thousands of Covered Entities and Business Associates with their Healthcare Insurance Portability and Accountability Act (HIPAA) compliance programs since the first release of the HITRUST CSF in 2009.

Is TeamViewer HIPAA compliant?

HIPAA Compliance TeamViewer provides remote access, remote support, and online collaboration capabilities with the level of security and privacy necessary for organizations to remain HIPAA compliant.

Does HITRUST replace HIPAA?

HITRUST does not replace HIPAA, but it can provide measurable criteria and objectives for applying "appropriate administrative, technical, and physical safeguards."

What is the difference between SOC 2 and HITRUST?

One of the main differences between a SOC 2 and HITRUST CSF is that a SOC 2 is an attestation report, while a HITRUST review is accompanied by a certification.

What are HITRUST controls?

The HITRUST CSF requires four controls related to information security risk management: Risk Management Program Development, Performing Risk Assessments, Risk Mitigation, and Risk Evaluation.

What is the difference between Hitech and HITRUST?

HITRUST, which was originally an acronym for The Health Information Trust Alliance, is not a law like HITECH. Rather, it is a company that has collaborated with an assortment of organizations to create a framework that can be used by all types of companies that store, transmit or create sensitive or regulated data.

Who needs HITRUST certification?

1. HITRUST compliance is required by all major healthcare payers in the US. No matter what your business does in the healthcare realm, it's crucial to know that HITRUST CSF certification is often required.

Is a VPN HIPAA compliant?

For many businesses, a Virtual Private Network (VPN) is one of the best and easiest ways to implement network security, protect data transmission, provide encryption and meet other HIPAA compliance requirements that secure electronic Protected Health Information (ePHI).

Is VNC HIPAA compliant?

Deploy at scale while keeping sessions safe with vigorous protection options and authentication tools that give you complete control. RealVNC is HIPAA compliant – find out more.

Is LogMeIn HIPAA compliant?

Yes, LogMeIn says that it is HIPAA compliant, and a signed business associate agreement (BAA) is available for corporate customers. LogMeIn is remote-access software that falls under the “technical safeguards” category of the Health Insurance Portability and Accountability Act (HIPAA).

What does HITRUST certification mean?

HITRUST certification means that the organization has undergone a thorough assessment of the information security program focused around a given scope which is generally limited to one or more implemented systems.

What does HITRUST stand for?

the Health Information Trust AllianceHITRUST stands for the Health Information Trust Alliance. It was founded in 2007 and uses the “HITRUST approach” to help organizations from all sectors–but especially healthcare–effectively manage data, information risk, and compliance.

Is HITRUST a law?

So what is the difference between HIPAA and HITRUST? HIPAA is a law and HITRUST is an organization.

What is the difference between HIPAA and Hitech?

The HIPAA Privacy Rule gave health plan members and patients the right to acquire copies of their PHI. HITECH expanded those rights to include receiving said copies in electronic form if the information was readily available in that format.

What is HIPAA law?

Though most are very familiar with the Health Insurance Portability and Accountability Act (HIPAA) and its relation to third parties and remote access, we’re going to break it down a bit. HIPAA carries with it data privacy requirements for individuals, organizations, and entities working with patient information.

How many records were exposed in the Quest Diagnostics data breach?

In June of 2019, both LabCorp and Quest Diagnostics experienced third-party data breaches that exposed 7.7 million and 11.9 million records, respectively. Included in the exposed records were names, date of birth, address, phone number, date of service, and more, according to TechCrunch, and ranged from August of 2018 until March of 2019.

Why is healthcare so heavily targeted for hackers?

The healthcare industry is still heavily targeted for hackers because of the wealth of information they can get. As someone that (I assume) has been to a doctor’s office of any sort, you know how many forms you have to fill out– all the information you have to give, all the releases you have to sign because of HIPAA/HITECH. When we, as patients, sign those papers and agree to hand over this information, we don’t think of all the vendors that might be also accessing that information. It’s imperative that healthcare systems that work with vendors ensure the security of PHI not only for HIPAA compliance, but for patient privacy too.

What should network managers know about patient access?

Network managers should always know who has access to patient information, the extent of that access, and how long it’s available. Third-party vendor access should have tight restrictions that limit time, scope and job function. In addition, every remote access session should begin with multi-factor authentication – then all activity must be logged, capturing a unique username and password tied to the individual.

What is the weakest point in data security?

The point of access is often the weak link in data security, and regularly the weakest point is vendors’ access to a larger hospital system network. A secure remote access platform eliminates many common gaps and poor third-party vendor practices that lead to data exposure and regulatory breach and can help you identify vulnerable vendors.

Is HIPAA compliance required for remote access?

When hospital systems provide remote access to third-party vendors without comprehensive controls, this compliance – and their overall network security – can be jeopardized. A HIPAA-compliant remote access policy isn’t just essential in the healthcare industry, but it’s necessary.

Is remote access required for HIPAA?

A HIPAA compliant remote access policy isn’t just essential in the healthcare industry, but it’s necessary. It’s important to remember that you can’t be in compliance if your vendors (or anyone external who has access to your “stuff”) aren’t compliant, too.

What is Azure Healthcare AI blueprint?

One method is using an Azure Healthcare AI blueprint. It’s a shortcut to using Microsoft Azure at low cost and without deep knowledge of cloud computing. Blueprints include resources such as example code, test data, security, and compliance support. The largest advantage of using a blueprint is explicit advice and clear instructions on keeping your solution in compliance. We’re trying to eliminate the mystery, so you don’t have to research it yourself.

Why is AI used in healthcare?

Many healthcare organizations are starting to adopt artificial intelligence (AI) systems to gain deeper insight into operations, patient care, diagnostic imaging, cost savings and so on. However, it can sometimes be daunting to even know where to get started.

What is the goal of the Shared Responsibilities for Cloud Computing document?

Preventing misunderstandings and setting clear expectations of responsibilities is the goal of the Shared Responsibilities for Cloud Computing document. If you are trying to meet HITRUST certification standards, the HITRUST Customer Responsibilities Matrix spreadsheet identifies exactly what Microsoft and the customer are respectively responsible for managing.

What is a blueprint for AI?

The blueprint includes a script to create an AI/ML system, complete with a sample experiment. It also includes several documents to help system implementers keep their installations secure and compliant. These include worksheets, whitepapers, and spreadsheets that will help you ensure system compliance with healthcare regulations and certifications. The artifacts are easily re-purposed for other healthcare-based systems implemented on Azure.

What are the areas of the blueprint?

Three core areas where the blueprint can help with compliance are cloud provider and client responsibilities, security threats, and regulatory compliance . These three areas can get overlooked at the beginning of any technology project, yet they are important parts of creating healthcare systems. Applying formal discipline to these areas is made easier by using the blueprint to create an AI/ML experiment installation.

What is security threat analysis?

A standard approach to security threat analysis involves identifying the surface area of your system, creating a model of that surface area, identifying potential threats, mitigating them and validating each mitigation, updating the threat model as you proceed. The following diagram highlights the major phases this process.

Why is it important to do a threat assessment?

It is a best practice to create a threat assessment model. It helps you to visualize the system and find the points of vulnerability in the proposed architecture. This leads to conversations about where the system may be improved and hardened against attacks.

What is Azure Healthcare AI blueprint?

One method is using an Azure Healthcare AI blueprint. It’s a shortcut to using Microsoft Azure at low cost and without deep knowledge of cloud computing. Blueprints include resources such as example code, test data, security, and compliance support. The largest advantage of using a blueprint is explicit advice and clear instructions on keeping your solution in compliance. We’re trying to eliminate the mystery, so you don’t have to research it yourself.

What is a blueprint for AI?

The blueprint includes a script to create an AI/ML system, complete with a sample experiment. It also includes several documents to help system implementers keep their installations secure and compliant. These include worksheets, whitepapers, and spreadsheets that will help you ensure system compliance with healthcare regulations and certifications. The artifacts are easily re-purposed for other healthcare-based systems implemented on Azure.

What is the goal of the Shared Responsibilities for Cloud Computing document?

Preventing misunderstandings and setting clear expectations of responsibilities is the goal of the Shared Responsibilities for Cloud Computing document. If you are trying to meet HITRUST certification standards, the HITRUST Customer Responsibilities Matrix spreadsheet identifies exactly what Microsoft and the customer are respectively responsible for managing.

What are the areas of the blueprint?

Three core areas where the blueprint can help with compliance are cloud provider and client responsibilities, security threats, and regulatory compliance . These three areas can get overlooked at the beginning of any technology project, yet they are important parts of creating healthcare systems. Applying formal discipline to these areas is made easier by using the blueprint to create an AI/ML experiment installation.

What is security threat analysis?

A standard approach to security threat analysis involves identifying the surface area of your system, creating a model of that surface area, identifying potential threats, mitigating them and validating each mitigation, updating the threat model as you proceed. The following diagram highlights the major phases this process.

Why is it important to do a threat assessment?

It is a best practice to create a threat assessment model. It helps you to visualize the system and find the points of vulnerability in the proposed architecture. This leads to conversations about where the system may be improved and hardened against attacks.

Who is responsible for the cloud?

When creating any system on a cloud platform, there are two possible owners for any part of the solution, the cloud provider and the customer. It is important to know who is responsible for specific actions, services, and other operational details. Without a clear understanding of this delineation, customers or vendors may find themselves in a difficult situation if an issue arises, like service outages or security breaches. Therefore, it is in everyone’s interest to be clear about the responsibilities of design and operations.

What is HIPAA law?

The Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the regulations issued under HIPAA are a set of U.S. healthcare laws that establish requirements for the use, disclosure, and safeguarding of individually identifiable health information. The scope of HIPAA was extended with the enactment of the Health Information ...

When was HIPAA extended?

The scope of HIPAA was extended with the enactment of the Health Information Technology for Economic and Clinical Health (HITECH) Act in 2009. HIPAA applies to covered entities (specifically, health care providers, health plans, and health care clearinghouses) that create, receive, maintain, transmit, or access patients' protected health ...

What is Microsoft HIPAA Business Associate Agreement?

The Microsoft HIPAA Business Associate Agreement is available through the Microsoft Online Services Data Protection Addendum by default to all customers who are covered entities or business associates under HIPAA. See 'Microsoft in-scope cloud services' on this webpage for the list of cloud services covered by this BAA.

Is HIPAA Business Associate Agreement available?

The HIPAA Business Associate Agreement is also available for in-scope Microsoft Professional Services upon. Contact your Microsoft services representative for more information.

Is Microsoft Azure covered by FedRAMP?

Microsoft enterprise cloud services are also covered by FedRAMP assessments. Microsoft Azure and Microsoft Azure Government received a Provisional Authority to Operate from the FedRAMP Joint Authorization Board; Microsoft Dynamics 365 U.S. Government received an Agency Authority to Operate from the US Department of Housing and Urban Development, as did Microsoft Office 365 U.S. Government from the U.S. Department of Health and Human Services.

Does Microsoft have a HIPAA certification?

There is currently no certification standard that is approved by the Department of Health and Human Services to demonstrate compliance with HIPAA or the HITECH Act by a business associate. However, Microsoft enables customers in their compliance with HIPAA and the HITECH Act and adheres to the Security Rule requirements of HIPAA in its capacity as a business associate. Moreover, Microsoft enters into Business Associate Agreements with its covered entity and business associate customers to support their compliance with HIPAA obligations.

Does Microsoft have to enter into contracts with PHI?

These contracts, or BAAs, clarify and limit how the business associate can handle PHI, and set forth each party's adherence to the security and privacy provisions set forth in HIPAA and the HITECH Act. Once a BAA is in place, Microsoft customers (covered entities) can use its services to process and store PHI.

What is total HIPAA?

Total HIPAA specializes in creating customized HIPAA-related documentation and training for our clients. We provide documents like Security Policies and Procedures, Disaster Recovery Policies, Confidentiality Agreements, and Bring Your Own Device (BYOD) Policies. For questions about policies, documentation, or best practices for remote employees, call us at 800.344.6381 or complete this form:

How to protect client's PHI?

How To Protect Your Clients’ PHI When Working Remotely 1 Make a list of remote employees. 2 Indicate the level of information to which they have access.

What is required to secure a network?

Devices must be encrypted, password protected, and installed with software firewalls and anti-virus software is installed.

Why do you need to sign a confidentiality agreement?

Have each employee sign a Confidentiality Agreement to assure the utmost privacy when handling PHI.

What is the mandate of a company for employees in violation of the procedures?

Mandate that any employees in violation of these procedures will be subject to the company’s Sanction Policy and/or civil and criminal penalties.

Do remote employees have to have rules?

First and foremost, if you have remote employees, you must set rules for them in your Security Policies and Procedures.

Is working remotely a risk?

While there are several advantages of working remotely, there’s a monstrous risk for those that are obligated to comply with HIPAA: keeping clients’ protected health information (PHI) safe. Not convinced it’s a big deal? HHS levies hefty financial penalties when entities fail to properly manage their telecommuters’ access and protection of PHI.

What is the HIPAA security rule for laptops?

All covered entities are required to be in compliance with the HIPAA Security Rule1, which includes, among its requirements, reviewing and modifying, where necessary, security policies and procedures on a regular basis. This is particularly relevant for organizations that allow remote access to EPHI through portable devices or on external systems or hardware not owned or managed by the covered entity.

What are the HIPAA rules?

The HIPAA Security and Privacy Rules require all covered entities to protect the EPHI that they use or disclose to business associates, trading partners or other entities. New standards and technologies have significantly simplified the way in which data is transmitted throughout the healthcare industry and created tremendous opportunities for improvements in the healthcare system. However, these technologies have also created complications and increased the risk of loss and unauthorized use and disclosure of this sensitive information.

What does covered entity need to do to protect EPHI?

Covered entities must develop and implement policies and procedures to protect EPHI that is stored on remote or portable devices, or on potentially transportable media (particularly backups).

What is the HIPAA Privacy Rule for EPHI?

It is important that only those workforce members who have been trained and have proper authorization are granted access to EPHI.

What is the procedure for a covered entity to lose EPHI?

Should a covered entity experience loss of EPHI via portable media, the entity’s security incident procedures must specify the actions workforce members must take to manage harmful effects of the loss. Procedures may include securing and preserving evidence; managing the harmful effects of improper use or disclosure; and notification to affected parties. Needless to say, such incidents should be evaluated as part of the entity’s ongoing risk management initiatives.

What is HIPAA One?

HIPAA One is the leading HIPAA Compliance Software and Services firm in the United States. Since its inception in 2012, HIPAA One has collected HIPAA compliance data for over 6,000 locations and audited thousands of healthcare organizations. HIPAA One employs a team of in-house certified Auditors/Security Practitioners and recently integrated their software with some of the nation’s largest electronic medical record companies such as athenahealth and Allscripts. HIPAA One aims to simplify HIPAA compliance through use of their automated, cloud-based software.

What is the HIPAA breach notification rule?

7 The HIPAA Breach Notification Rule, 45 CFR §§ 164.400-414, requires HIPAA covered entities and their business associates to provide notification following a breach of unsecured protected health information.

What is the HIPAA Privacy Rule?

The HIPAA Privacy Rule, at a high level , ensures individuals have the minimum protections under the law. Incorrect configuration of modern operating systems, including Office 365, could violate the following laws and may lead to HIPAA non-compliance:

How will GDPR impact healthcare providers?

companies do not need to have business operations in one of the 28-member states of the European Union to be impacted by GDPR. GDPR requires all organizations who process EU/EEA residents' data to support a high level of privacy protection and account for where that data is stored. GDPR only applies to organizations that are considered “established” in the EU. Being “established” in the EU does not necessary require the physical presence of a corporate entity. Rather, an organization is “established” to the extent that it exercises “effective and real” activity in the EU, and processes personal data in the context of those activities, through “stable arrangements.” The legal form of those arrangements is not determinative and could be met by the presence of an employee or agent." Even in circumstances where a US company engages in no activities that would render it established in the EU, it can still be subject to GDPR if it offers goods or services to EU data subjects or monitors the behavior of EU data subjects within the EU. GDPR is not triggered simply because a US company offers goods or services to EU data subjects.

What is PHI in healthcare?

PHI is defined as information about an individual’s health care, created, received or maintained by a health care provider, that identifies an individual or with respect to which there is a reasonable basis to believe the information can be used to identify the individual. PHI includes information related to the past, present or future physical or mental health or condition of an individual; information about the provision of health care to an individual; and information related to the past, present or future payment for the provision of health care to an individual." “Personal data,” is defined as any information relating to an identified or identifiable natural person who is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

How long does it take to report a breach to HHS?

Timing:To individuals without unreasonable delay and no later than 60 calendar days after discovery of the breach. For breaches affecting 500 or more individuals, to HHS and the media without unreasonable delay and no later than 60 calendar days after discovery of the breach. For breaches affecting less than 500 individuals, to HHS within 60 days after the end of the calendar year during which the breach occurred.

What is the GDPR?

The General Data Protection Regulation(“GDPR”) is a data protection law in the European Union (“EU”) and the European Economic Area (“EEA”) that gives individuals control over their data and provides data protection, globally. The law also requires organizations to bolster their privacy and data protection measures and imposes significant penalties and fines up to the greater of €20 million or 4% of annual global revenue for those who violated its provisions.

What is HIPAA security rule?

The HIPAA Security Rule requires covered entities (CEs) to employ physical, technical and administrative controls to protect PHI. These safeguards include installing software patches promptly, keeping anti-virus definitions up to date and regularly scanning for viruses.

How many records were exposed in the Anthem hack?

Deceiving users into revealing passwords and other valuable information such as encryption security keys has been the method hackers used to gain access to huge databases of patient records, such as the intrusion at Anthem Inc., that resulted in the exposure of 78.8 million records and the HIPAA breach at Premera Health that is believed to have affected 11 million individuals, including exposing their Social Security numbers and healthcare data.

Why should CEs use encryption?

Given the number of data breaches that occur each year due to lost and stolen devices and the considerable cost of dealing with security breaches, CEs should give serious consideration to using data encryption or other methods to keep PHI protected in case of theft or loss of portable devices.

How can viruses and malware get through security systems?

Viruses and malware can get through security systems when staff makes simple mistakes. It is therefore essential that the staff receives training not only on HIPAA Privacy and Security Rules, but also on how to identify phishing schemes, malware and other malicious programs. Policies should be in place to restrict the websites that users can view and what they are permitted to download, as far as it is possible without restricting their ability to do their jobs.

How convincing is phishing?

Phishing emails can be very convincing. Hackers spend a considerable amount of time and money designing emails to mimic those of service providers and other individuals that would appear to legitimately require user credentials to be supplied. It only takes one person to respond to provide login credentials for access to be gained and security measures to be bypassed.

What is phishing campaign?

Phishing campaigns can result in security measures being bypassed and security keys being obtained. Alternative – or additional – security measures can be employed such as the use of tracking software on portable devices, to at least be able to recover the data and put a stop to the breach.

What is Verizon's security breach?

The Verizon security report indicated that in 99.9% of cases of security breaches caused by unaddressed security vulnerabilities, it was the failure to install software patches that caused the security breach. Software is released; security flaws are discovered; patches are issued to plug those security gaps. Software updates are often issued following successful attacks to prevent further intrusions. Developers have a constant job on their hands to keep operating systems and other software up to date and secure.

Closing the BMS Security Gap

As cyberattacks increase in frequency and sophistication, the need to protect sensitive and personal data is becoming more critical than ever. Medical organizations and healthcare providers must remain vigilant, continuously monitoring their networks to ensure no malware is lurking behind the scenes.

Manage HIPAA Compliance With Tenable

Tenable.sc™ (formerly SecurityCenter®) provides continuous monitoring for healthcare providers, and facilitates and ensures HIPAA security rule compliance by:

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Helpful Artifacts

Clarifying Responsibilities

  • When creating any system on a cloud platform, there are two possible owners for any part of the solution, the cloud provider and the customer. It is important to know who is responsible for specific actions, services, and other operational details. Without a clear understanding of this delineation, customers or vendors may find themselves in a difficult situation if an issue arises, l…
See more on azure.microsoft.com

Planning For Security Threats

  • Before creating complex systems, it is always advisable to perform a threat assessment. It is a best practice to create a threat assessment model. It helps you to visualize the system and find the points of vulnerability in the proposed architecture. This leads to conversations about where the system may be improved and hardened against attacks. Microsoft provides a Threat Model …
See more on azure.microsoft.com

Regulatory Compliance

  • Healthcare systems need to meet regulatory compliance standards. At installation, the blueprint complies with HIPAA and HITRUST requirements. Whitepapers are included to help you understand how to continue to meet these requirements. Let’s examine the whitepapers and other provided artifacts to see how they might help.
See more on azure.microsoft.com

Recommended Next Steps

  • Use the supporting collateral below to prepare for your installation of the blueprint. The artifacts demonstrate how responsibilities, compliance, and security are established and how you can maintain them going forward. Prepare for installation and ongoing maintenance with the following documents. 1. The Azure blueprint for AI Solution Guide. 2. Shared Responsibilities for Cloud Co…
See more on azure.microsoft.com

Collaboration

  • What other artifacts or considerations do you think would be helpful when putting healthcare systems into production? Your comments and recommendations are welcome below. I regularly post on technology in healthcare topics. Reach out and connect with me on LinkedIn or Twitter.
See more on azure.microsoft.com

Helpful Artifacts

Clarifying Responsibilities

Planning For Security Threats

Regulatory Compliance

  • Healthcare systems need to meet regulatory compliance standards. At installation, the blueprint complies with HIPAA and HITRUST requirements. Whitepapers are included to help you understand how to continue to meet these requirements. Let’s examine the whitepapers and other provided artifacts to see how they might help.
See more on azure.microsoft.com

Recommended Next Steps

Collaboration

Hipaa and The Hitech Act Overview

Microsoft, HIPAA, and The Hitech Act

Third-Party Certifications

Microsoft In-Scope Cloud Platforms & Services

Azure, Dynamics 365, and Hipaa

Office 365 and Hipaa

  • Office 365 environments
    Microsoft Office 365 is a multi-tenant hyperscale cloud platform and an integrated experience of apps and services available to customers in several regions worldwide. Most Office 365 services enable customers to specify the region where their customer data is located. Microsoft may repl…
  • Office 365 applicability and in-scope services
    Use the following table to determine applicability for your Office 365 services and subscription:
See more on docs.microsoft.com

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