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Security of eHealth Information HIPAA Compliance at HRA. Group: GTR ver M Grace Chen Taru Singhal Robert Szymanek Michael Parker. Agenda. Identify the Problem Compliance/Risk Storage Options Transmission Options Feasibility Analysis Final Recommendation. Identify the Problem.
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Security of eHealth InformationHIPAA Compliance at HRA • Group: GTR ver M • Grace Chen • Taru Singhal • Robert Szymanek • Michael Parker
Agenda • Identify the Problem • Compliance/Risk • Storage Options • Transmission Options • Feasibility Analysis • Final Recommendation
Identify the Problem • Deficiencies in the process of storage/backup • Is the current data stored? • Is there a secure backup currently performed? • Is current data encrypted? • Currently how is data archived? • Deficiencies in the process of transmission • What is the best way to transmit data? • What Is the best encryption • Is E-mail safe? ftp/sftp?
Types of Sensitive Information • Social Security numbers • Home addresses and telephone numbers • Personal and family health history • Bank accounts and credit card numbers
Why Compliance? • The HIPAA Privacy Rule applies to: • Health plans • Healthcare clearinghouses, part of an HIO • Healthcare providers that conduct covered transactions • Healthcare Information Organization (HIO) performs certain functions or activities which require access to PHI • Healthcare clearinghouses collect data such as PHI and data-mine them
Risk of Non-Compliance • Federal Penalties • The U.S. Department of Health & Human Services has the authority to impose penalties of $100 to $50,000 or more per violation. • Criminal Penalties • The U.S. Department of Justice has the right to fine organizations and individuals who intentionally violate standards. The penalties range from $50,000 to $250,000, with various jail sentence lengths, depending on the offense.
Protect the organization! • Encrypt data on servers and email • Restrict use of file sharing applications and portable devices • Provide protection against malware and attacks • Use comprehensive security policies • Log data points for compliance audits
Storage of Protected Health Information Opt 1: Data Center/Iron Mountain Opt 2: Citrix Solution/Iron Mountain
Opt 1: Data Center Infrastructure • SAN/Servers - $160,000 • Cisco - $24,000 • VMware/Failover - $26,000 • Applications (VeriSign, sftp) - $10,500 • Contractors - $9,400 • Total - $229,900
Opt 2: Citrix Solution • Citrix Access Gateway protects data using standards-based encryption technologies (SSL/TLS). • Secure remote access. • Leading SSL VPN performance and scalability. • Protect intellectual property with corporate policies. • Lets users work from anywhere.
Citrix Solution Estimate • Data Center (1,000 users) - $229,900 • Same expense as for both solutions.
Opt 1/2: Iron Mountain Services • Rapid recovery • Extremely high security • Reduce risk of server data loss and downtime • Continuous backup • Protection of open files and databases • Flexible retention periods • Access when and where you want it • http://www.ironmountain.com/health-information/health-server-backup.html
Opt 1/2: Iron Mountain Expenses • $2.15 per GB per month • HIPAA Retention Period is 7 years Operating expense, non-capital
Transmission of Protected Health Information
Data Transmission - Secure FTP • Secure FTP can be used as a technical mechanism, protecting data in motion within a distributed healthcare system. • Secure Shell password controls file access. • Secure Shell encryption controls confidentiality of the information. • Server Event logs facilitates a security audit.
Data Transmission - Secure Email • The primary rule within HIPAA that affects e-mail is the Security Rule. • Many encryption technologies require the user to become familiar with the use of plug-ins and other specialized “client-side” encryption software • Another issue faced by organizations is a lack of technological standards • The solution to each of these issues is to move the encryption responsibility from the individual user to a specialized server.
Solution Implementation • The team is ready to implement a multi-layered system using the Data Center storage and Iron Mountain • Secure transmission using secure ftp and secure email for transmission of Protected Health Information. • Provision sufficient resources to implement a Citrix solution when needed, plan for FY 2012 or FY 2013.
Feasibility Analysis • New Deployments (No teardown) • Storage/backup • Secure Email • Secure FTP • Maintenance Considerations for IT staff • Ensuring complete backups (Iron Mountain) • Enforcing Data Center SLA standards • Checking secure local storage • Maintaining VeriSign certificates for email and FTP • Processes invisible to end users!
The SolutionData Center – InfrastructureIron Mountain – Secure Backup • Iron Mountain (2.5 TB) - $193,500 • Iron Mountain is an annual operating expense at $64,500/year • Operating costs affect Income Statement • Data Center (Infrastructure required) - $229,900 • A capital expense at depreciates at $45,980/year over 5 years • Capital expenses affect the Balance Sheet • Maintenance approx 10% of purchase price, capitalized • Total - $412,900
Thank You Questions?