Based on the work of

1. Voice over the Internet Protocol (VoIP) Technologies:How to Select a Videoconferencing System for Your Agency Based on the work of Watzlaf, V.M., Fahima, R., Moeini, S. & Firouzani, P. (2010). VOIP for telerehabilitation: A risk analysis for privacy, security, and HIPAA compliance. International Journal of Telerehabilitation, 3-14.

2. Selecting a Platform

3. Most VoIP technology systems provide a very reliable, high quality, and competent teleconferencing session with patients.However, to determine if the VoIP videoconferencing technologies are private, secure, and compliant with HIPAA, a risk analysis should be performed. Watzlaf, et al., 2010

4. Skype, Vsee, or Other Vendors • Questions regarding 3 HIPAA requirements • Audit trails • Chat box information stored on company’s computers • VSee can track which accounts connect but does not know the time or the content • For a review of vendors visit: • http://www.telementalhealthcomparisons.com/ (You will have to provide your email address to review the comparisons)

5. Let’s take specific vendorsOUT of the discussion

6. 2 Choices

7. 1st CHOICE • Use the HIPAA compliance checklist (Watzlaf et al., 2010) • Compare it to the VoIP technology software privacy and security policies provided by the software vendor • Ask if they are willing to enter into a BAA (Business Associate Agreement)

8. Purchase HIPAA compliant software specific to VoIP with vendors that will walk you through each piece of the HIPAA legislation to make certain the software is private and secure and be willing to enter into a BAA (Business Associate Agreement) 2nd CHOICE

9. HIPAA Compliance Checklist for VoIP (located on NFAR website)

10. Example of Items on Checklist • Personal Information • Will employees and other users of VoIP software be able to listen in to video-therapy calls between patient and therapist? • Retention of Personal Information • Are video conferencing sessions for therapy services recorded? • Requests for Information from Legal Authorities etc • Will personal information, communications content, and/or traffic data when requested by legal authorities be provided by the VoIP software company?

11. Every potential user (therapist or healthcare facility) should review the privacy and security policies that are found on the VoIP software system’s website to determine if they answer the questions listed in this checklist.If the question is not addressed in the policy, then the user may want to contact the software company and ask them how the company will address a particular question(s).

12. Next Steps…

13. 1. Form a team that will examine VoIP software systems to determine if it meets federal (HIPAA), state, local, and facility-wide privacy and security regulations.

14. The team may consist of the • Provider attorney • Risk management personnel • Health information administrator or privacy officer • Security office (IT) • Clinical directors/supervisors • Counselors

15. 2. Designate someone on the team to stay on top of all the changes videoconferencing software systems(federal state and local)

16. 3. Educate all staff (not just counselors) on how to use software system for videoconferencing

17. Training should include: Privacy and Security related to HIPAA Issues Related to PHI (Private Health Information) Exchange Encryption Spyware Password Security Use of Equipment by Counselor/Client ATA Guidelines

18. 4. Develop Patient Informed Consent Form What therapy will be provided using the VoIP technology How the technology will be used Benefits associated with videoconferencing Risks associated with videoconferencing (privacy and security) Informed Consent Form reviewed by team attorney

19. 5. Incident response is necessary and should include… • documentation regarding the incident • response to the incident • any effects of the incident, as well as whether policies and procedures were followed • if policies and procedures are not in place for incident response, then these should be developed with the security and privacy officers

20. Suggested General RULES for VoIP (Kuhn, Walsh, & Fries, 2005, National Institute of Standards and Technology)

21. Do not use the username and password for anything other than videoconferencing; change it frequently; and do not make it easy to identify RULES

22. Avoid getting computer viruses on the computer used for video conferencing RULES

23. Never use it for emergency services RULES

24. Consistently authenticate who you are communicating with especially when used for tele-therapy video sessions RULES

25. Focus on: • the transmission of data through videoconferencing • how that data is made private and secure during the telecommunication • how private and secure it is stored and released to internal and outside entities RULES

26. Provide audit controls for using software applications so that they are secure and private RULES

27. There arethreetypes of informationsecurity risks: • Confidentiality • Integrity • Availability

28. Confidentialityrefers to the need to keep information secure and private.

29. Integrityrefers to information remaining unaltered by unauthorized users.

30. Availabilityincludes making information and services available for use when necessary.

31. VoIP Risks and Recommendationsrelated to Confidentiality, Integrity, and AvailabilityList on NFAR Website

32. Information Security Risk & Recommendation Example (See VoIP Risks and Recommendations Checklist)

33. Thank you to Dr. Watzlaf and colleagues for allowing us to use their article as the basis for this presentation and to post the HIPAA Compliance Checklist, and Risk and Recommendations List on our Website

34. www.nfarattc.org