hitech and hipaa compliance higher availability privacy auditing

23
2010 © FairWarning, Inc. Private and Confidential 2011 Executive Webinar Series HITECH and HIPAA Compliance: High Availability Privacy Auditing and Monitoring View the Replay

Upload: phungtruc

Post on 14-Feb-2017

218 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

2011 Executive Webinar Series

HITECH and HIPAA Compliance: High Availability Privacy Auditing and Monitoring

View the Replay

Page 2: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

Today’s Agenda

• Introduction

• Privacy Monitoring Availability & Scale– Randy Yates, Memorial Hermann Healthcare System

• Privacy Monitoring Challenges for Large Health Systems– Kurt Long, FairWarning®

• Questions & Answers

Page 3: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

Drivers for Today’s Webinar

• “Always-on” Privacy Monitoring– ARRA HITECH privacy requirements, breach disclosure, penalties, other

– Meaningful use, risk assessments, gaps, future considerations

– Regulatory requirements for increased data retention

– Increased media exposure to major privacy lapses

Page 4: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial RANDY YATES, DIRECTOR OF SECURITY

MEMORIAL HERMANN HEALTHCARE SYSTEM

Page 5: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

Memorial Hermann Healthcare System

• Randy is responsible for enterprise data security solutions, account management and security risk management. He provides risk assessment services to business owners to ensure that both technology and business objectives are accomplished with secure controls for protection of company confidential and patient data. He oversees HIPAA security, PCI compliance and is currently assessing the impacts of the ARRA HITECH legislations that was recently in acted. He has implemented several security technologies including tape backup encryption, hard disk encryption, email encryption, transportable media encryption and identify management solutions.

• Prior to joining MH, Randy served as a security consultant for IBM Global Services division, Security consultant for Healthlink, a healthcare IT focused professional service firm, CRM consultant for Cambridge technology partners and as an IT audit Manager for International Paper Company. His primary consulting engagements included security strategic planning, security plan development and HIPAA security compliance assessments and implementations. Randy earned a BS in Business Administration from Mississippi State University.

Page 6: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

Memorial Hermann Healthcare System

• Largest not-for-profit healthcare system in Texas and serves the greater Houston community through 11 hospitals, a vast network of affiliated physicians and numerous specialty programs and services.

– Memorial Hermann-Texas Medical Center, the teaching hospital for The University of Texas Medical School at Houston and home of the nation’s busiest Level I trauma center;

– 8 suburban hospitals;

– 3 premier Heart & Vascular Institutes;

– TIRR Memorial Hermann, one of the nation’s top rehabilitation and research hospitals;

– Children’s Memorial Hermann Hospital;

– Memorial Hermann Sports Medicine Institute;

– Mischer Neuroscience Institute;

– 8 comprehensive Cancer Centers; 21 Imaging Centers;

– 8 Breast Care Centers;

– 10 surgery centers;

– 25 sports medicine and rehabilitation centers;

– 19 diagnostic laboratories; and

– PaRC, a substance abuse treatment center.

– Memorial Hermann also operates the Life Flight® air ambulance program as well as the city’s only burn treatment center.

• Award-winning: Most Wired 100, Most Wired 2009, Thomson Reuters 100 Top Hospital

• Employees 20,000

• Total Beds 3,200

• Cerner, McKesson, GE, CGI Sovera, ArcSight

Page 7: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

The Challenge

• Reporting in each clinical application – some semi-automated, most a manual effort

• No consolidated solution• We tried Sensage but it only worked for our primary EMR – it lacked

reporting and the querying was slow• We tried P2 Sentinel but was a “silo” – only did one application, Cerner

Millennium, and we have 128 different systems

• Wanted reporting across our clinical applications• Wanted proactive breach detection• Wanted advanced reporting with filtering using our HR data, staff

location, etc.

• Needed a scale-able solution• Needed investigative and auditing capability for HIPAA compliance

– Including HIPAA regulations on storing our data

Page 8: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

Why We Chose FairWarning®

• Competitive Bidding Situation

• HP Partner and HP Appliance Servers• ArcSight Partner and Enterprise Security Product Integration • McKesson Partner and McKesson-Certified Application

• The number of clinical applications that FairWarning® had already worked with was by far greater than any other

• Excellent Customer References, KLAS Scores• FairWarning® business-friendly interface and ease of reporting for

our Privacy Office • IT and Security Office evaluated the technical and scaling aspects

and gave full sign-off

Page 9: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

Solution Set Up and Testing

• Followed the FairWarning® Standard for Cerner Millennium data

• Near Real Time Service (hourly)

• Documented our Test Cases; Extensive Testing with the FairWarning® Team

– Tried to ‘break’ FairWarning capabilities with “the big data dump”

– Graphs of processing power “barely a ‘blip’ on the graph”

– Load Testing with Production Level Traffic

– Performance Testing• No Cerner Queuing

– Stability Testing

– Failover Testing with 2 Servers5 different Test Cases

• P2 Sentinel / Sensagedecommissioned from our environment

Page 10: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

Memorial Hermann’s FairWarning® Solution

Patient Privacy Breach Detection and Protection

HIPAA Compliance

Page 11: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

Memorial Hermann’s FairWarning® Solution

• Data Stats:

– Peak hour of data is usually 11am-12pm with up to 200,000 transactions sent from Cerner to FairWarning.

– Daily 6 GB of data being collected and 3 million auditable events being written into FairWarning.

• Experience To-Date

Page 12: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial KURT LONG, FOUNDER

FAIRWARNING®

Page 13: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

Privacy Monitoring Challenges in a Large Health System

• Availability and scale

• Large numbers of application audit sources

• Filtering out false positives

• Advanced analytics

• Integration with enterprise security

• Real time considerations

• Work-flow supporting reporting, remediation, sanctioning and audits

Page 14: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

Standard & HA Configurations

Others

Best available protocol, https, sFTP, other

Hot-spare

Optional Configuration for High Performance and Availability –Proven and Cost Effective

High Availability and Scaling• Reporting & monitoring failover to hot-spare • Reporting & monitoring can run from Hot-spare (option)• Audit log consumption fail-over to Hot-spare (option)

Architecture• MySQL 5.5 database with partitioning optimized by FairWarning®• Data replication between primary and hot-spare• 2 to 4 years of on-board storage, archival for much longer periods

Primary

Page 15: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

FairWarning® Customer Community

• 100 + major enterprise healthcare providers, 18 new in Q4 2010 alone

• Represent 450 hospitals and 2,100 clinics

• United States, Canada, United Kingdom

• 50 % + have received prestigious awards for quality

• Range in size from 1,000 to 50,000 + employees

• Note: FairWarning® now has offices in London, England and Paris, France

Page 16: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

KLAS & FairWarning®

Based on KLAS interviews with customers:

• 100% indicate FairWarning® is part of their long-term plans

• 100% indicate they would purchase FairWarning® again

• 100% indicate FairWarning® keeps its promises

More information is available at: http://www.KLASresearch.com/

Page 17: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

Privacy Monitoring Challengesand the Patient Privacy Framework

• Large numbers of application audit sources

• Advanced Analytics

• Filtering out false positives

• Integration with Enterprise Security

• Real-time monitoring

• Work-flow supporting reporting, remediation, sanctioning and audits

• No detailed standards, guidelines or data definitions related to healthcare privacy auditing & monitoring

Page 18: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

FairWarning® Data Definition Guide

Predictable, consistent integration with EHRs, ERP and identity management

Best data practices

Large numbers of applications

Advanced Analytics & Filtering

Real-time architectures

Available since Summer 2010

Open copyright

FairWarning® Ready SI’s

FairWarning® Ready MPIs

FairWarning® Customers

FairWarning® Patient Privacy FrameworkGuide 1: Data Definition Guide

Page 19: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

Enterprise security Data Definition Guide

ISO visibility for patient incidents

Privacy monitoring & SIEM, DLP cooperative correlation

End-to-end trace

Real-time considerations

Available since Fall 2010

Open copyright

FairWarning® Customers

FairWarning® Ready SIEM-DLP

FairWarning® Patient Privacy FrameworkGuide 2: Enterprise security data definitions

Page 20: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

Implementation Toolkit

The business processes of privacy monitoring

Gaining Board & Executive buy-in

Human resource & legal considerations

Work-flows for remediation

Communication & sanctioning templates

Detailed project plan templates

Available since January 1, 2011

FairWarning® Customers

FairWarning® Ready “Gold”

FairWarning® Patient Privacy FrameworkGuide 3: Implementation Toolkit

Page 21: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

Industry Support FairWarning® Patient Privacy Framework Guides

“Data definitions for EHR enterprise and departmental

system audit logs will prove to be very useful to

healthcare providers seeking to normalize and

automate their response to HITECH’s privacy auditing

requirements surrounding protected health information

(PHI) and consultants and vendors looking to assist

them. The guides should increase their understanding

of the sources and structure of the PHI.”

Barry Runyon, Research VP at Gartner

"For the first time in this industry, there is data that

quantifies the risk of not proactively and systematically

monitoring for breaches. More importantly, this newly

released report proves that policy without enforcement

doesn't work and creates entity-wide risk through

empirical data. For EHRs to be successful and to secure

public trust, the industry as a whole must commit to

establishing ongoing breach monitoring, an environment

of informed compliance and effective risk mitigation."

Mac McMillan, Chair, HIMSS Privacy & Security

Steering Committee, & CEO, CynergisTek

"Security and privacy breaches threaten to undermine the

public's trust in health IT and electronic health information

exchange - just at the time when policymakers are actively

promoting it. This report [Breach Findings] demonstrates that

implementation of industry best practices reduces the risk of

breach and is key to enabling more widespread adoption and

use of e-health technologies."

Deven McGraw, Director of the Health Privacy Project,

Center for Democracy and Technology

"Historically healthcare providers have relied on intensive

and manual procedures to monitor for breaches. As a result,

many of these entities are unaware of the actual number of

breaches within their organizations and therefore unable to

report or thwart these breaches. What should be eye-

opening for these organizations that do not have a reliable

automated monitoring process, is the vast financial and

reputational risk posed by any one of these breaches."

Cliff Baker, Managing Partner, Meditology and Executive

Advisor HITRUST Alliance LLC

Page 22: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial

FairWarning® Resources

Available after today’s webinar:

High availability configurations

FairWarning® and Meaningful Use

Patient Privacy Framework Guides

ROI Calculator on privacy monitoring

Real-time architecture for privacy monitoring

Breach Damages Estimator Based on breach monitoring deployments as well as

interviews with health systems, legal counsel and 3rd-parties involved with high-profile breaches and audits

White paper on privacy breach findings

Both available by [email protected]

Page 23: HITECH and HIPAA Compliance Higher Availability Privacy Auditing

20

10

© F

airW

arn

ing,

Inc.

–P

riva

te a

nd

Co

nfi

den

tial QUESTIONS & ANSWERS