Healthcare Compliance GotchasHealthcare Compliance Gotchas

information Healthcare - October 2010

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Healthcare companies have obvious high-risk areas to watch when it comes to ensuring the safety of personal health data. And as doctors' offices and hospitals do more business on plastic, guaranteeing the safety of credit and debit card data is another rising concern.

The Health Insurance Portability and Accountability Act lays down a range of controls and processes to safeguard personal health data, and the Payment Card Industry's data security standard defines how to protect credit and debit card data.

But even with a well thought out security program and a clear understanding of HIPAA and PCI mandates, some controls get overlooked. This is particularly true in large healthcare organizations with dynamic IT infrastructures that must evolve to meet the needs of tech-heavy applications. What follows are eight areas to keep an eye on, and ways you can ensure they're secure.

1) Off-Site Resources: Third-party service providers, including individuals working out of small and home offices, are often tapped to do data entry and other processing. Whenever sensitive data is being handled in a less structured setting, there's room for mistakes.

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Ensure better security by having off-site workers use company equipment that's pre-configured with required security controls. Also, require whole disk encryption on all devices that reside outside the physical office if any sensitive data is kept on them. Minimize the portability of sensitive data. And if a remote terminal service connection is used to access data, don't allow that data to be saved locally, screen scraped, or printed unless there's a clear and convincing business requirement to do so.

2) Business Partners: Connections to business partners, such as suppliers and laboratories, must be carefully managed to detect and stop incidents such as an uncontrolled worm arriving from a partner's network. You'll want to put connectivity agreements in place that state why connections are being created and what systems partners need to access. Also, name a person on each side responsible for the connection. Revisit a partner's need for the connectivity at least annually, and terminate unneeded connectivity.

3) Food: Large healthcare providers often overlook cafeterias and other facilities that take credit cards when implementing PCI security standards, but they're subject to the same data protection requirements as any commercial establishment.

If credit card data is sent to a payment processor, then you're likely not storing data on-premises, and PCI compliance is simpler in that case. If payments are collected using an internal payment program with payment data traversing and being stored on your network, then you'll likely need more extensive controls around the cardholder data repositories.

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Download the October 2010 issue of information Healthcare