Voice over the Internet Protocol (VoIP) Technologies…

How to Select a Videoconferencing System for Your Agency

Based on the Work ofWatzlaf, 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

Selecting a Platform

Most VoIP technology systems provide a very reliable, high quality, and competent teleconferencing session with their

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

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 these comparisons

Let’s Take Specific Vendors OUT of the Discussion

2 Choices

1st CHOICE

Use the HIPAA compliance checklist (prepared by Watzlaf & colleagues) and

compare it to the VoIP technology software privacy and security policies

provided by the software vendor and ask if they are willing to enter into a BAA

(Business Associate Agreement)

2nd CHOICE

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)

HIPAA Compliance Checklist for VoIPChecklist on NFAR website

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?

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).

Next Steps……

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

The team may consist of the provider attorney, risk

management personnel, health information administrator/

privacy officer, security officer (IT), clinical directors/

supervisors and counselors

2. Designate someone on the team to stay on top of all the changes

videoconferencing software systems

(federal state and local)

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

videoconferencing

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

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

5. Incident response is necessary and should include….

• documentation regarding the incident• the response to the incident, any effects of the

incident as well as whether policies and procedures that were followed in response to the incident

• if policies and procedures are not in place for incident response, then these should be developed with the security and privacy officers

Suggested General Rules for VoIP

Kuhn, Walsh, & Fries, 2005National Institute of Standards and Technology

Do not use the username and password for anything else but videoconferencing, change it frequently and do not make it

easy to identify

Avoid having computer viruses on the computer used for video

conferencing

Never use it for emergency services

Consistently authenticate who you are communicating with

especially when used for tele-therapy video sessions

Focus on the transmission of data through video conferencing…..

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.

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

There are three types of

information security risks: Confidentiality, Integrity, and Availability

Confidentiality refers to the need to keep information secure and

private.

Integrity refers to information remaining unaltered by unauthorized

users.

Availability includes making information and services available for use

when necessary.

VoIP Risks and Recommendationsrelated to

Confidentiality, Integrity, and AvailabilityList on NFAR Website

Information Security Risk & Recommendation Example

Risk, Vulnerability or Threat

Specific Area Risk Level Recommendation

Confidentiality & Privacy

Retention of personal data & information as well as eavesdropping on conversations

High

(increases in VoIP because of the many nodes in a packet network)

Change default passwords

disable remote access to graphical user interface use authentication mechanisms

See VoIP Risks and Recommendations Checklist

All credit for this presentation goes toDr. Watzlaf and colleagues for allowing the

use of their article as the basis for this presentation and allowing us to post the HIPAA Compliance Checklist and the Risk

and Recommendations List on our Website

www.nfarattc.org