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Mobile Health Security Issues To Ponder In 2016

Posted on January 11, 2016 I Written By

Anne Zieger is a healthcare journalist who has written about the industry for 30 years. Her work has appeared in all of the leading healthcare industry publications, and she's served as editor in chief of several healthcare B2B sites.

In some ways, mobile health security safeguards haven’t changed much for quite some time. Making sure that tablets and phones are protected against becoming easy network intrusion points is a given. Also seeing to it that such devices use strong passwords and encrypted data exchange whenever possible is a must.

But increasingly, as mobile apps become more tightly knit with enterprise infrastructure, there’s more security issues to consider. After all, we’re increasingly talking about mission-critical apps which rely on ongoing access to sensitive enterprise networks. Now more than ever, enterprises must come up with strategies which control how data flows into the enterprise network. In other words, we’re not just talking about locking down the end points, but also seeing to it that powerful edge devices are treated like the vulnerable hackable gateways they are.

To date, however, there’s still not a lot of well-accepted guidance out there spelling out what steps health organizations should take to ramp up their mobile security. For example, NIST has issued its “Securing Electronic Health Records On Mobile Devices” guideline, but it’s only a few months old and remains in draft form to date.

The truth is, the healthcare industry isn’t as aware of, or prepared for, the need for mobile healthcare data security as it should be. While healthcare organizations are gradually deploying, testing and rolling out new mobile platforms, securing them isn’t being given enough attention. What’s more, clinicians aren’t being given enough training to protect their mobile devices from hacks, which leaves some extremely valuable data open to the world.

Nonetheless, there are a few core approaches which can be torqued up help protect mobile health data this year:

  • Encryption: Encrypting data in transit wasn’t invented yesterday, but it’s still worth a check in to make sure your organization is doing so. Gregory Cave notes that data should be encrypted when communicated between the (mobile) application and the server. And he recommends that Web traffic be transmitted through a secure connection using only strong security protocols like Secure Sockets Layer or Transport Layer Security. This also should include encrypting data at rest.
  • Application hardening:  Before your organization rolls out mobile applications, it’s best to see to it that security defects are detected before and addressed before deployment. Application hardening tools — which protect code from hackers — can help protect mobile deployments, an especially important step for software placed on machines and locations your organization doesn’t control. They employ techniques such as obfuscation, which hides code structure and flow within an application, making it hard for intruders to reverse engineer or tamper with the source code.
  • Training staff: Regardless of how sophisticated your security systems are, they’re not going to do much good if your staff leaves the proverbial barn door open. As one security expert points out,  healthcare organizations need to make staffers responsible for understanding what activities lead to breaches, or security hackers will still find a toehold.”It’s like installing the most sophisticated security system in the world for your house, but not teaching the family how to use it,” said Grant Elliott, founder and CEO of risk management and compliance firm Ostendio.

In addition to these efforts, I’d argue that staffers need to really get it as to what happens when security goes awry. Knowing that mistakes will upset some IT guy they’ve never met is one thing; understanding that a breach could cost millions and expose the whole organization to disrepute is a bit more memorable. Don’t just teach the security protocols, teach the costs of violating them. A little drama — such as the little old lady who lost her home due to PHI theft — speaks far more powerfully than facts and figures, don’t you agree?

Tiny Budgets Undercut Healthcare’s Cyber Security Efforts

Posted on January 4, 2016 I Written By

Anne Zieger is a healthcare journalist who has written about the industry for 30 years. Her work has appeared in all of the leading healthcare industry publications, and she's served as editor in chief of several healthcare B2B sites.

This has been a lousy year for healthcare data security — so bad a year that IBM has dubbed 2015 “The Year of The Healthcare Security Breach.” In a recent report, Big Blue noted that nearly 100 million records were compromised during the first 10 months of this year.

Part of the reason for the growth in healthcare data breaches seems to be due to the growing value of Protected Health Information. PHI is worth 10x as much as credit card information these days, according to some estimates. It’s hardly surprising that cyber criminals are eager to rob PHI databases.

But another reason for the hacks may be — to my way of looking at things — an indefensible refusal to spend enough on cybersecurity. While the average healthcare organization spends about 3% of their IT budget on cybersecurity, they should really allocate 10% , according to HIMSS cybersecurity expert Lisa Gallagher.

If a healthcare organization has an anemic security budget, they may find it difficult to attract a senior healthcare security pro to join their team. Such professionals are costly to recruit, and command salaries in the $200K to $225K range. And unless you’re a high-profile institution, the competition for such seasoned pros can be fierce. In fact, even high-profile institutions have a challenge recruiting security professionals.

Still, that doesn’t let healthcare organizations off the hook. In fact, the need to tighten healthcare data security is likely to grow more urgent over time, not less. Not only are data thieves after existing PHI stores, and prepared to exploit traditional network vulnerabilities, current trends are giving them new ways to crash the gates.

After all, mobile devices are increasingly being granted access to critical data assets, including PHI. Securing the mix of corporate and personal devices that might access the data, as well as any apps an organization rolls out, is not a job for the inexperienced or the unsophisticated. It takes a well-rounded infosec pro to address not only mobile vulnerabilities, but vulnerabilities in the systems that dish data to these devices.

Not only that, hospitals need to take care to secure their networks as devices such as insulin pumps and heart rate monitors become new gateways data thieves can use to attack their networks. In fact, virtually any node on the emerging Internet of Things can easily serve as a point of compromise.

No one is suggesting that healthcare organizations don’t care about security. But as many wiser heads than mine have pointed out, too many seem to base their security budget on the hope-and-pray model — as in hoping and praying that their luck will hold.

But as a professional observer and a patient, I find such an attitude to be extremely reckless. Personally, I would be quite inclined to drop any provider that allowed my information to be compromised, regardless of excuses. And spending far less on security than is appropriate leaves the barn door wide open.

I don’t know about you, readers, but I say “Not with my horses!”

Are These Types of Breaches Really Necessary?

Posted on December 28, 2015 I Written By

Anne Zieger is a healthcare journalist who has written about the industry for 30 years. Her work has appeared in all of the leading healthcare industry publications, and she's served as editor in chief of several healthcare B2B sites.

Over the past couple of days, I took the time to look over Verizon’s 2015 Protected Health Information Data Breach Report.  (You can get it here, though you’ll have to register.)

While it contained many interesting data points and observation — including that 90% percent of the industries researchers studied had seen a personal health information breach this year — the stat that stood out for me was the following. Apparently, almost half (45.5%) of PHI breaches were due to the lost or theft of assets. Meanwhile, issue of privileges and miscellaneous errors came in at distant second and third, at just over 20% of breaches each.

In case you’re the type who likes all the boxes checked, the rest of the PHI breach-causing list, dubbed the “Nefarious Nine,” include “everything else” at 6.7%, point of sale (3.8%), web applications (1.9%), crimeware, (1.4%), cyber-espionage (0.3%), payment card skimmers (0.1%) and denial of service at a big fat zero percent.

According to the report’s authors, lost and stolen assets have been among the most common vectors for PHI exposure for several years. This is particularly troubling given that one of the common categories of breach — theft of a laptop — involves data which was not encrypted.

If stolen or lost assets continue to be a problem year after year, why haven’t companies done more to address this problem?

In the case of firms outside of the healthcare business, it’s less of a surprise, as there are fewer regulations mandating that they protect PHI. While they may have, say, employee worker’s compensation data on a laptop, that isn’t the core of what they do, so their security strategy probably doesn’t focus on safeguarding such data.

But when it comes to healthcare organizations — especially providers — the lack of data encryption is far more puzzling.

As the report’s authors point out, it’s true that encrypting data can be risky in some situations; after all, no one wants to be fumbling with passwords, codes or biometrics if a patient’s health is at risk.

That being said, my best guess is that if a patient is in serious trouble, clinicians will be attending to patients within a hospital. And in that setting, they’re likely to use a connected hospital computer, not a pesky, easily-stealable laptop, tablet or phone. And even if life-saving data is stored on a portable device, why not encrypt at least some of it?

If HIPAA fears and good old common sense aren’t good enough reasons to encrypt that portable PHI, what about the cost of breaches?  According to one estimate, data breaches cost the healthcare industry $6 billion per year, and breaches cost the average healthcare organization $3.5 million per year.

Then there’s the hard-to-measure cost to a healthcare organization’s brand. Patients are becoming increasingly aware that their data might be vulnerable, and a publicly-announced breach might give them a good reason to seek care elsewhere.

Bottom line, it would be nice to see out industry take a disciplined approach to securing easily-stolen portable PHI. After years of being reminded that this is a serious issue, it’s about time to institute a crackdown.

Hospital CFO Insights from Craneware Summit

Posted on October 22, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Today I had a chance to attend the Craneware Summit in Las Vegas. The Craneware Summit gives me a nice view into what’s happening in the financial world of healthcare. The Summit kicked off today with Todd Nelson speaking about the hospital CFO. Here’s a look at some of the insights he offered:


Todd Nelson is a former hospital CFO that is now a VP at HFMA.


Is this equation too simple?


I don’t think that meaningful use money will go away, but it’s worth considering. Would your organization survive if the rest of the meaningful use money were pulled out from underneath you?


This is often forgotten. It’s “easy” to get the billion dollar EHR implementation budget, but many forget to include the ongoing EHR support and optimization budget. In my experience this is often just bad planning, but in a few cases it’s done deliberately in order to allow the EHR project to go forward. They figure they can always ask for the support and optimization budget later.


This was an interesting comment coming from an accountant and former hospital CFO. He was willing to admit that he doesn’t have the skill or at least the desire to be the actuary for the hospital. However, as we shift to value based reimbursement, hospitals are going to have to become good at actuarial analysis.


Todd Nelson also extended this comment by saying that you can survive a long time even with losses as long as you have the cash. If you’ve worked with a hospital CFO, you’ve probably seen the cash focus first hand. That hasn’t and probably won’t change.


This is great advice as hospital executives evaluate how to approach the changing healthcare reimbursement environment. Hope is not a strategy.

HIM Departments Need More Support

Posted on July 16, 2015 I Written By

Anne Zieger is a healthcare journalist who has written about the industry for 30 years. Her work has appeared in all of the leading healthcare industry publications, and she's served as editor in chief of several healthcare B2B sites.

As both a contributor to this blog, and an assertive, activist patient managing chronic conditions, I get to see both sides of professional health information management.  And I have to say that while health data management pros obviously do great things against great odds, support for their work doesn’t seem to have trickled down to the front lines.  I’m speaking most specifically about Medical Records (oops, I mean Health Information Management) departments in hospitals.

As I noted in a related blog post, I recently had a small run-in with the HIM department of a local hospital which seems emblematic of this problem. The snag occurred when I reached out to DC-based Sibley Memorial Hospital and tried to get a new log-in code for their implementation of Epic PHR MyChart. The clerk answering the phone for that department told me, quite inaccurately, that if I didn’t use the activation code provided on my discharge summary papers within two days, my chance to log in to the Johns Hopkins MyChart site was forever lost. (Sibley is part of the Johns Hopkins system.)

Being the pushy type that I am, I complained to management, who put me in touch with the MyChart tech support office. The very smart and help tech support staffer who reached out to me expressed surprise at what I’d been told as a) the code wasn’t yet expired and b) given that I supplied the right security information she’d have been able to supply me with a new one.  The thing is, I never would have gotten to her if I hadn’t known not to take the HIM clerk’s word at face value.

Note: After writing the linked article, I was able to speak to the HIM department leader at Sibley, and she told me that she planned to address the issue of supporting MyChart questions with her entire staff. She seemed to agree completely that they had a vital role in the success of the PHR and patient empowerment generally, and I commend her for that.

Now, I realize that HIM departments are facing what may be the biggest changes in their history, and that Madame Clerk may have been an anomaly or even a temp. But assuming she was a regular hire, how much training would it have taken for the department managers to require her to simply give out the MyChart tech support number? Ten minutes?  Five? A priority e-mail demanding that PHR/digital medical record calls be routed this way would probably have done the trick.

My take on all of this is that HIM departments seem to have a lot of growing up to do. Responsible largely for pushing paper — very important paper but paper nonetheless — they’re now in the thick of the health data revolution without having a central role in it. They aren’t attached to the IT department, really, nor are they directly supporting physicians — they’re sort of a legacy department that hasn’t got as clearly defined a role as it did.

I’m not suggesting that HIM departments be wiped off the map, but it seems to me that some aggressive measures are in order to loop them in to today’s world.

Obviously, training on patient health data access is an issue. If HIM staffers know more about patient portals generally — and ideally, have hands-on experience with them, they’ll be in a better position to support such initiatives without needing to parrot facts blindly. In other words, they’ll do better if they have context.

HIM departments should also be well informed as to EMR and other health data system developments. Sure, the senior people in the department may already be looped in, but they should share that knowledge at brown bag lunches and staff update sessions freely and often. As I see it, this provides the team with much-needed sense of participation in the broader HIT enterprise.

Also, HIM staff members should encourage patients who call to log in and leverage patient portals. Patients who call the hospital with only a vague sense that they can access their health data online will get routed to that department by the switchboard. HIM needs to be well prepared to support them.

These concerns should only become more important as Meaningful Use Stage 3 comes on deck. MU Stage 3 should provide the acid test as to whether whether hospital HIM departments are really ready to embrace change.

Phase 2 HIPAA Audits Kick Off With Random Surveys

Posted on June 9, 2015 I Written By

Anne Zieger is a healthcare journalist who has written about the industry for 30 years. Her work has appeared in all of the leading healthcare industry publications, and she's served as editor in chief of several healthcare B2B sites.

Ideally, the only reason you would know about the following is due to scribes such as myself — but for the record, the HHS Office for Civil Rights has sent out a bunch of pre-audit screening surveys to covered entities. Once it gets responses, it will do a Phase 2 audit not only of covered entities but also business associates, so things should get heated.

While these take the form of Meaningful Use audits, covering incentives paid from January 1, 2011 through June 30, 2014, it’s really more about checking how well you protect ePHI.

This effort is a drive to be sure that providers and BAs are complying with the HIPAA privacy, security and breach notification requirements. Apparently OCR found, during Phase 1 pilot audits in 2011 and 2012, that there was “pervasive non-compliance” with regs designed to safeguard protected health information, the National Law Review reports.

However, these audits aren’t targeting the “bad guys.” Selection for the audits is random, according to HHS Office of the Inspector General.

So if you get one of the dreaded pre-screening letters, how should you respond? According a thoughtful blog post by Maryanne Lambert for CureMD, auditors will be focused on the following areas:

  • Risk Assessment audits and reports
  • EHR security plan
  • Organizational chart
  • Network diagram
  • EHR web sites and patient portals
  • Policies and procedures
  • System inventory
  • Tools to perform vulnerability scans
  • Central log and event reports
  • EHR system users list
  • Contractors supporting the EHR and network perimeter devices.

According to Lambert, the feds will want to talk to the person primarily responsible for each of these areas, a process which could quickly devolve into a disaster if those people aren’t prepared. She recommends that if you’re selected for an audit, you run through a mock audit ahead of time to make sure these staff members can answer questions about how well policies and processed are followed.

Not that anyone would take the presence of HHS on their premises lightly, but it’s worth bearing in mind that a stumble in one corner of your operation could have widespread consequences. Lambert notes that in addition to defending your security precautions, you have to make sure that all parts of your organization are in line:

Be mindful while planning for this audit as deficiencies identified for one physician in a physician group or one hospital within a multi-hospital system, may apply to the other physicians and hospitals using the same EHR system and/or implementing meaningful use in the same way.  Thus, the incentive payments at risk in this audit may be greater than the payments to the particular provider being audited.

But as she points out, there is one possible benefit to being audited. If you prepare well, it might save you not only trouble with HHS but possibly lawsuits for breaches of information. Hey, everything has some kind of silver lining, right?

Thinking About Future EHR Switching When Purchasing EHR Software

Posted on February 24, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

When we start purchasing our EHR, many times we don’t spend enough time thinking about what happens when we reach the end of life for the software we’re purchasing. I was particularly reminded of this when writing my post about the legacy EHR ticking time bombs. During our EHR or other healthcare IT software purchase, we don’t think about 5, 10, 15 years down the road when we might want to switch systems. What happens at the end of a system’s life is not our concern during an EHR purchase, but it should be.

A lot of people like to talk about EHR data portability. This is a very important subject when you’re looking to sunset an old system. However, if you haven’t put the right items in your EHR contract, it becomes a major issue for you to get that data out of the EHR. If you haven’t read the section on EHR contracts in my now somewhat dated EMR selection e-Book, take some time to read it over and check out your EHR contract.

When you can’t get the data out of your EHR, then you’re stuck in a situation that I described in my legacy EHR ticking time bomb post. You limp your legacy EHR system along and have issues with updates, fear the lost of the system completely, and much more. It’s just an ugly situation.

It’s nice to think that an EHR system will just work forever, but technology changes. It’s just the reality of life. I’m interested to see if the concept of an EHR vendor neutral archive will really take off. That would be one major way to combat this. However, I think many are afraid of this option because it’s tough to preserve the granular data elements in the EHR. Plus, it takes a forward thinking CIO to be able to make the investment in it. Although I’ve met some that are doing just this.

What has your organization done to prepare for the day that you’ll sunset your EHR or other healthcare IT systems? Is this a concern for you? Or are you like some CIOs who figure that it will be someone else’s problem?

Were Anthem, CHS Cyber Security Breaches Due to Negligence?

Posted on February 19, 2015 I Written By

Anne Zieger is a healthcare journalist who has written about the industry for 30 years. Her work has appeared in all of the leading healthcare industry publications, and she's served as editor in chief of several healthcare B2B sites.

Not long ago, health insurance giant Anthem suffered a security breach of historic proportions, one which exposed personal data on as many as 80 million current and former customers. While Anthem is taking steps to repair the public relations damage, it’s beginning to look like even its $100 million cyber security insurance policy is ludicrously inadequate to address what could be an $8B to $16B problem. (That’s assuming, as many cyber security pros do, that it costs $100 to $200 per customer exposed to restore normalcy.)

But the full extent of the healthcare industry hack may be even greater than that. As information begins to filter out about what happens, a Forbes report suggests that the cyber security intrusion at Anthem may be linked to another security breach — exposing 4.5 million records — that took place less than six months months ago at Community Health Systems:

Analysis of open source information on the cybercriminal infrastructure likely used to siphon 80 million Social Security numbers and other sensitive data from health insurance giant Anthem suggests the attackers may have first gained a foothold in April 2014, nine months before the company says it discovered the intrusion. Brian KrebsAnthem Breach May Have Started in April, 2014

Class action suits against CHS were filed last August, alleging negligence by the hospital giant. Anthem also faces class action suits alleging security negligence in Indiana, California, Alabama and Georgia. But the damage to both companies’ image has already been done, damage that can’t be repaired by even the most favorable legal outcome. (In fact, the longer these cases linger in court, the more time the public has to permanently brand the defendants as having been irresponsible.)

What makes these exploits particularly unfortunate is that they may have been quite preventable. Security experts say Anthem, along with CHS, may well have been hit by a well-known and frequently leveraged vulnerability in the OpenSSL cryptographic software library known as the Heartbleed Bug. A fix for Heartbleed, which was introduced in 2011, has been available since April of last year. Though outside experts haven’t drawn final conclusions, many have surmised that neither Anthem nor CHS made the necessary fix which would  have protected them against Heartbleed.

Both companies have released defensive statements contending that these security breaches were due to tremendously sophisticated attacks — something they’d have to do even if a third-grade script kiddie hacked their infrastructure. But the truth is, note security analysts, the attacks almost certainly succeeded because of a serious lack of internal controls.

By gaining admin credentials to the database there was nothing ‒ including encryption ‒ to stop the attack. The only thing that did stop it was a lucky administrator who happened to be paying attention at the right time. Ken Westin – Senior Security Analyst at Tripwire

As much these companies would like to convince us that the cyber security breaches weren’t really their fault — that they were victims of exotic hacker gods with otherworldly skills — the bottom line is that this doesn’t seem to be true.

If Anthem and CHS going to point fingers rather than stiffen up their cyber security protocols, I’d advise that they a) buy a lot more security breach insurance and b) hire a new PR firm.  What they’re doing obviously isn’t working.

HL7 Backs Effort To Boost Patient Data Exchange

Posted on December 8, 2014 I Written By

Anne Zieger is a healthcare journalist who has written about the industry for 30 years. Her work has appeared in all of the leading healthcare industry publications, and she's served as editor in chief of several healthcare B2B sites.

Standards group Health Level Seven has kicked off a new project intended to increase the adoption of tech standards designed to improve electronic patient data exchange. The initiative, the Argonaut Project, includes just five EMR vendors and four provider organizations, but it seems to have some interesting and substantial goals.

Participating vendors include Athenahealth, Cerner, Epic, McKesson and MEDITECH, while providers include Beth Israel Deaconess Medical Center, Intermoutain  Healthcare, Mayo Clinic and Partners HealthCare. In an interesting twist, the group also includes SMART, Boston Children’s Hospital Informatics Program’s federally-funded mobile app development project. (How often does mobile get a seat at the table when interoperability is being discussed?) And consulting firm the Advisory Board Company is also involved.

Unlike the activity around the much-bruited CommonWell Alliance, which still feels like vaporware to industry watchers like myself, this project seems to have a solid technical footing. On the recommendation of a group of science advisors known as JASON, the group is working at creating a public API to advance EMR interoperability.

The springboard for its efforts is HL7’s Fast Healthcare Interoperability Resources. HL7’s FHir is a RESTful API, an approach which, the standards group notes, makes it easier to share data not only across traditional networks and EMR-sharing modular components, but also to mobile devices, web-based applications and cloud communications.

According to JASON’s David McCallie, Cerner’s president of medical informatics, the group has an intriguing goal. Members’ intent is to develop a health IT operating system such as those used by Apple and Android mobile devices. Once that was created, providers could then use both built-in apps resident in the OS and others created by independent developers. While the devices a “health IT OS” would have to embrace would be far more diverse than those run by Android or iOS, the concept is still a fascinating one.

It’s also neat to hear that the collective has committed itself to a fairly aggressive timeline, promising to accelerate current FHIT development to provide hands-on FHIR profiles and implementation guides to the healthcare world by spring of next year.

Lest I seem too critical of CommonWell, which has been soldiering along for quite some time now, it’s onlyt fair to note that its goals are, if anything, even more ambitious than the Argonauts’. CommonWell hopes to accomplish nothing less than managing a single identity for every person/patient, locating the person’s records in the network and managing consent. And CommonWell member Cerner recently announced that it would provide CommonWell services to its clients for free until Jan. 1, 2018.

But as things stand, I’d wager that the Argonauts (I love that name!) will get more done, more quickly. I’m truly eager to see what emerges from their efforts.

HIPAA Slip Leads To PHI Being Posted on Facebook

Posted on July 1, 2014 I Written By

Anne Zieger is a healthcare journalist who has written about the industry for 30 years. Her work has appeared in all of the leading healthcare industry publications, and she's served as editor in chief of several healthcare B2B sites.

HHS has begun investigating a HIPAA breach at the University of Cincinnati Medical Center which ended with a patient’s STD status being posted on Facebook.

The disaster — for both the hospital and the patient — happened when a financial services employee shared detailed medical information with father of the patient’s then-unborn baby.  The father took the information, which included an STD diagnosis, and posted it publicly on Facebook, ridiculing the patient in the process.

The hospital fired the employee in question once it learned about the incident (and a related lawsuit) but there’s some question as to whether it reported the breach to HHS. The hospital says that it informed HHS about the breach in a timely manner, and has proof that it did so, but according to HealthcareITNews, the HHS Office of Civil Rights hadn’t heard about the breach when questioned by a reporter lastweek.

While the public posting of data and personal attacks on the patient weren’t done by the (ex) employee, that may or may not play a factor in how HHS sees the case. Given HHS’ increasingly low tolerance for breaches of any kind, I’d be surprised if the hospital didn’t end up facing a million-dollar OCR fine in addition to whatever liabilities it incurs from the privacy lawsuit.

HHS may be losing its patience because the pace of HIPAA violations doesn’t seem to be slowing.  Sometimes, breaches are taking place due to a lack of the most basic security protocols. (See this piece on last year’s wackiest HIPAA violations for a taste of what I’m talking about.)

Ultimately, some breaches will occur because a criminal outsmarted the hospital or medical practice. But sadly, far more seem to take place because providers have failed to give their staff an adequate education on why security measures matter. Experts note that staffers need to know not just what to do, but why they should do it, if you want them to act appropriately in unexpected situations.

While we’ll never know for sure, the financial staffer who gave the vengeful father his girlfriend’s PHI may not have known he was  up to no good. But the truth is, he should have.