It comes as no surprise to information technology security professionals that data leaks and privacy issues can occur at virtually any level of an organization including business associates, contractors, subs-contractors and outsourced firms like payroll and billing. With this, it is has been a long time coming that the U.S. Department of Health and Human Services (HHS) update their guidelines to extend security and privacy requirements to organizations and individuals that do business on behalf of the health care provider.
The amended Health Insurance Portability and Accountability Act (HIPAA) Privacy and Security rules, which provide statutory governance for the the Health Information Technology for Economic and Clinical Health Act (HITECH), has now formalized requirements for when data breaches must be reported to HHS and penalties for non-compliance. These revisions also include criteria for any organization or individuals that handle Protected Health Information (PHI) on behalf of the parent entity. According to Leon Rodriguez, the Director for Civil Rights at HHS, "These changes not only greatly enhance a patient's privacy rights and protections, but also strengthen the ability of my office to vigorously enforce the HIPAA privacy and security protections, regardless of whether the information is being held by a health plan, a health care providers, or one of their business associates."
For information technology professionals performing vulnerability management to secure patient data, the scope of your assessments has just increased to include entities outside of your organization. This represents a new challenge for legal contracts, assessments, and auditing of affiliate data and systems in order to document compliance. It will not longer be possible to shrug off their security problems, inadequate policies, and faulty operations. Your organizations IT security department has now become a part of the bigger umbrella to secure Protected Health Information (PHI) at all of your businesses affailiates.
For users of Retina, our solutions are capable of providing HIPAA based regulatory reporting to verify asset security at the device or organizational level. Our management platform, Retina CS, supports multi-tenant environments, and can be easily configured to manage vulnerability data to support any affiliate business organization that your expanded scope may warrant. This configuration not only will allow you to continue to assess your own environment, but bring in air gapped and off line data from an associate business for reporting without having "data bleed". Below is an example of this type of reporting for a single organization:
If your business has not begun reporting vulnerability management data in terms of regulatory compliance initiatives such as HIPAA or HITRUST, now is a good time to get started since these updates will be upon us soon. If you are, a simple license expansion of Retina, and some basic configuration will be all you need to manage the additional assets within your scope.
These new rules will take affect March 26. Businesses and their associates will have until September 23, 2013 in order to comply. For more information on how BeyondTrust can you with HIPAA compliance,
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