Information Security Compliance: HIPAA

Eric Vanderburg

 

This is the first entry in a set of three blogs that deal with information compliance. We wish to provide corporations a guide that outlines which laws they are subject to and how to follow them properly.  In this particular blog we will discuss the Health Insurance Portability and Accountability Act (HIPAA).  A brief overview of the act will be included, as well as a discussion of where HIPAA applies and some of the requirements.

HIPAA is regulation intended to help covered entities and their business associates protect Electronic Protected Health Information (ePHI).  The U.S. Department of Health and Human Services (HHS) outlines who HIPAA applies to in their definition of a covered entity.  In addition to those seen in the diagram below, HIPAA applies to companies that provide services that would use e-PHI such as suppliers or outsourced IT providers.

http://www.hhs.gov/ocr/privacy/hipaa/understanding/coveredentities/index.html

Now that we know who this applies to we can discuss the basics of HIPAA compliance.  The primary goal of HIPAA is to protect ePHI which includes, name, dates such as birth, admission, discharge, death, telephone number, SSN, photographs, address, etc.  Companies under this regulation will need to implement technical and procedural controls to protect this information and perform risk analysis on risk and vulnerabilities to the confidentiality, integrity, and availability of ePHI.   Technical controls include such things as encryption, authentication, password complexity, access auditing, segmentation, etc., and procedural controls include such things as password policies, incident response plans, contingency plans, and audit procedures.

HIPAA also requires companies to provide patients with information on their privacy practices and they must record acknowledgement that the patient received the information.  You have most likely experienced this at the doctor’s office.

The covered entity or business associate must provide a plan outlining how the company will follow the act and designate someone who is responsible for creating and implementing policies to support the plan.  If a company outsources certain business processes then the company must make sure that the third party is also in compliance with HIPAA standards.

This article is too short to go into detail on the controls necessary for an organization but each system that houses or transmits ePHI will need to have adequate controls and each person who works with ePHI will have to follow procedures intended to protect this private information.  The scope of HIPAA compliance can be quite broad.  Included under this wide umbrella are doctor’s offices and other medical fields for the protection of patients. Certain businesses are also included.  Any company that gives its employees a degree of healthcare are bound to follow the confidentiality rules as well as the uniformity rules.  HIPAA defines a covered healthcare provider as a person or business that deals with healthcare in the normal course of the business day, and does so electronically.

This first installment in a series of blogs about information security compliance dealt with the medically related HIPAA or Health Insurance Portability and Accountability Act of 1996.  We defined it and included a summarization of the applications of HIPAA.  Finally, we included an overview of which companies should be concerned with the application and therefore the implementation of HIPAA.

http://en.wikipedia.org/wiki/Health_Insurance_Portability_and_Accountability_Act#Title_I:_Health_Care_Access.2C_Portability.2C_and_Renewability

http://www.cms.gov/hipaageninfo/downloads/CoveredEntityCharts.pdf

http://www.cms.gov/hipaageninfo/01_Overview.asp#TopOfPage

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