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Security and Privacy Are Pushing Archiving of Legacy EHR Systems

Posted on September 21, 2016 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.

In a recent McAfee Labs Threats Report, they said that “On average, a company detects 17 data loss incidents per day.” That stat is almost too hard to comprehend. No doubt it makes HIPAA compliance officers’ heads spin.

What’s even more disturbing from a healthcare perspective is that the report identifies hospitals as the easy targets for ransomware and that the attacks are relatively unsophisticated. Plus, one of the biggest healthcare security vulnerabilities is legacy systems. This is no surprise to me since I know so many healthcare organizations that set aside, forget about, or de-prioritize security when it comes to legacy systems. Legacy system security is the ticking time bomb of HIPAA compliance for most healthcare organizations.

In a recent EHR archiving infographic and archival whitepaper, Galen Healthcare Solutions highlighted that “50% of health systems are projected to be on second-generation technology by 2020.” From a technology perspective, we’re all saying that it’s about time we shift to next generation technology in healthcare. However, from a security and privacy perspective, this move is really scary. This means that 50% of health systems are going to have to secure legacy healthcare technology. If you take into account smaller IT systems, 100% of health systems have to manage (and secure) legacy technology.

Unlike other industries where you can decommission legacy systems, the same is not true in healthcare where Federal and State laws require retention of health data for lengthy periods of time. Galen Healthcare Solutions’ infographic offered this great chart to illustrate the legacy healthcare system retention requirements across the country:
healthcare-legacy-system-retention-requirements

Every healthcare CIO better have a solid strategy for how they’re going to deal with legacy EHR and other health IT systems. This includes ensuring easy access to legacy data along with ensuring that the legacy system is secure.

While many health systems use to leave their legacy systems running off in the corner of their data center or a random desk in their hospital, I’m seeing more and more healthcare organizations consolidating their EHR and health IT systems into some sort of healthcare data archive. Galen Healthcare Solution has put together this really impressive whitepaper that dives into all the details associated with healthcare data archives.

There are a lot of advantages to healthcare data archives. It retains the data to meet record retention laws, provides easy access to the data by end users, and simplifies the security process since you then only have to secure one health data archive instead of multiple legacy systems. While some think that EHR data archiving is expensive, it turns out that the ROI is much better than you’d expect when you factor in the maintenance costs associated with legacy systems together with the security risks associated with these outdated systems and other compliance and access issues that come with legacy systems.

I have no doubt that as EHR vendors and health IT systems continue consolidating, we’re going to have an explosion of legacy EHR systems that need to be managed and dealt with by every healthcare organization. Those organizations that treat this lightly will likely pay the price when their legacy systems are breached and their organization is stuck in the news for all the wrong reasons.

Galen Healthcare Solutions is a sponsor of the Tackling EHR & EMR Transition Series of blog posts on Hospital EMR and EHR.

Will a Duo of AI and Machine Learning Catch Data Thieves Lurking in Hospital EHR Corridors?

Posted on September 19, 2016 I Written By

The following is a guest blog post by Santosh Varughese, President of Cognetyx, an organization devoted to using artificial intelligence and machine learning innovation to bring an end to the theft of patient medical data.
santosh-varughese-president-cognetyx
As Halloween approaches, the usual spate of horror movies will intrigue audiences across the US, replete with slashers named Jason or Freddie running amuck in the corridors of all too easily accessible hospitals. They grab a hospital gown and the zombies fit right in.  While this is just a movie you can turn off, the real horror of patient data theft can follow you.

(I know how terrible this type of crime can be. I myself have been the victim of a data theft by hackers who stole my deceased father’s medical files, running up more than $300,000 in false charges. I am still disputing on-going bills that have been accruing for the last 15 years).

Unfortunately, this horror movie scenario is similar to how data thefts often occur at medical facilities. In 2015, the healthcare industry was one of the top three hardest hit industries with serious data breaches and major attacks, along with government and manufacturers. Packed with a wealth of exploitable information such as credit card data, email addresses, Social Security numbers, employment information and medical history records, much of which will remain valid for years, if not decades and fetch a high price on the black market.

Who Are The Hackers?
It is commonly believed attacks are from outside intruders looking to steal valuable patient data and 45 percent of the hacks are external. However, “phantom” hackers are also often your colleagues, employees and business associates who are unwittingly careless in the use of passwords or lured by phishing schemes that open the door for data thieves. Not only is data stolen, but privacy violations are insidious.

The problem is not only high-tech, but also low-tech, requiring that providers across the continuum simply become smarter about data protection and privacy issues. Medical facilities are finding they must teach doctors and nurses not to click on suspicious links.

For healthcare consultants, here is a great opportunity to not only help end this industry wide problem, but build up your client base by implementing some new technologies to help medical facilities bring an end to data theft.  With EHRs being more vulnerable than ever before, CIOs and CISOs are looking for new solutions.  These range from thwarting accidental and purposeful hackers by implementing physical security procedures to securing network hardware and storage media through measures like maintaining a visitor log and installing security cameras. Also limiting physical access to server rooms and restricting the ability to remove devices from secure areas.

Of course enterprise solutions for the entire hospital system using new innovations are the best way to cast a digital safety net over all IT operations and leaving administrators and patients with a sense of security and safety.

Growing Nightmare
Medical data theft is a growing national nightmare.  IDC’s Health Insights group predicts that 1 in 3 healthcare recipients will be the victim of a medical data breach in 2016.  Other surveys found that in the last two years, 89% of healthcare organizations reported at least one data breach, with 79% reporting two or more breaches. The most commonly compromised data are medical records, followed by billing and insurance records. The average cost of a healthcare data breach is about $2.2 million.

At health insurer Anthem, Inc., foreign hackers stole up to 80 million records using social engineering to dig their way into the company’s network using the credentials of five tech workers. The hackers stole names, Social Security numbers and other sensitive information, but were thwarted when an Anthem computer system administrator discovered outsiders were using his own security credentials to log into the company system and to hack databases.

Investigators believe the hackers somehow compromised the tech worker’s security through a phishing scheme that tricked the employee into unknowingly revealing a password or downloading malicious software. Using this login information, they were able to access the company’s database and steal files.

Healthcare Hacks Spread Hospital Mayhem in Diabolical Ways
Not only is current patient data security an issue, but thieves can also drain the electronic economic blood from hospitals’ jugular vein—its IT systems. Hospitals increasingly rely on cloud delivery of big enterprise data from start-ups like iCare that can predict epidemics, cure disease, and avoid preventable deaths. They also add Personal Health Record apps to the system from fitness apps like FitBit and Jawbone.

Banner Health, operating 29 hospitals in Arizona, had to notify millions of individuals that their data was exposed. The breach began when hackers gained access to payment card processing systems at some of its food and beverage outlets. That apparently also opened the door to the attackers accessing a variety of healthcare-related information.

Because Banner Health says its breach began with an attack on payment systems, it differentiates from other recent hacker breaches. While payment system attacks have plagued the retail sector, they are almost unheard of by healthcare entities.

What also makes this breach more concerning is the question of how did hackers access healthcare systems after breaching payment systems at food/beverage facilities, when these networks should be completely separated from one another? Healthcare system networks are very complex and become more complicated as other business functions are added to the infrastructure – even those that don’t necessarily have anything to do with systems handling and protected health information.

Who hasn’t heard of “ransomware”? The first reported attack was Hollywood Presbyterian Medical Center which had its EHR and clinical information systems shut down for more than week. The systems were restored after the hospital paid $17,000 in Bitcoins.

Will Data Thieves Also Rob Us of Advances in Healthcare Technology?
Is the data theft at MedStar Health, a major healthcare system in the DC region, a foreboding sign that an industry racing to digitize and interoperate EHRs is facing a new kind of security threat that it is ill-equipped to handle? Hospitals are focused on keeping patient data from falling into the wrong hands, but attacks at MedStar and other hospitals highlight an even more frightening downside of security breaches—as hospitals strive for IT interoperability. Is this goal now a concern?

As hospitals increasingly depend on EHRs and other IT systems to coordinate care, communicate critical health data and avoid medication errors, they could also be risking patients’ well-being when hackers strike. While chasing the latest medical innovations, healthcare facilities are rapidly learning that caring for patients also means protecting their medical records and technology systems against theft and privacy violations.

“We continue the struggle to integrate EHR systems,” says anesthesiologist Dr. Donald M. Voltz, Medical Director of the Main Operating Room at Aultman Hospital in Canton, OH, and an advocate and expert on EHR interoperability. “We can’t allow patient data theft and privacy violations to become an insurmountable problem and curtail the critical technology initiative of resolving health system interoperability. Billions have been pumped into this initiative and it can’t be risked.”

Taking Healthcare Security Seriously
Healthcare is an easy target. Its security systems tend to be less mature than those of other industries, such as finance and tech. Its doctors and nurses depend on data to perform time-sensitive and life-saving work.

Where a financial-services firm might spend a third of its budget on information technology, hospitals spend only about 2% to 3%. Healthcare providers are averaging less than 6% of their information technology budget expenditures on security, according to a recent HIMSS survey. In contrast, the federal government spends 16% of its IT budget on security, while financial and banking institutions spend 12% to 15%.

Meanwhile, the number of healthcare attacks over the last five years has increased 125%, as the industry has become an easy target. Personal health information is 50 times more valuable on the black market than financial information. Stolen patient health records can fetch as much as $363 per record.

“If you’re a hacker… would you go to Fidelity or an underfunded hospital?” says John Halamka, the chief information officer of Beth Israel Deaconess Medical Center in Boston. “You’re going to go where the money is and the safe is the easiest to open.”

Many healthcare executives believe that the healthcare industry is at greater risk of breaches than other industries. Despite these concerns, many organizations have either decreased their cyber security budgets or kept them the same. While the healthcare industry has traditionally spent a small fraction of its budget on cyber defense, it has also not shored up its technical systems against hackers.

Disrupting the Healthcare Security Industry with Behavior Analysis   
Common defenses in trying to keep patient data safe have included firewalls and keeping the organization’s operating systems, software, anti-virus packages and other protective solutions up-to-date.  This task of constantly updating and patching security gaps or holes is ongoing and will invariably be less than 100% functional at any given time.  However, with only about 10% of healthcare organizations not having experienced a data breach, sophisticated hackers are clearly penetrating through these perimeter defenses and winning the healthcare data security war. So it’s time for a disruption.

Many organizations employ network surveillance tactics to prevent the misuse of login credentials. These involve the use of behavior analysis, a technique that the financial industry uses to detect credit card fraud. By adding some leading innovation, behavior analysis can offer C-suite healthcare executives a cutting-edge, game-changing innovation.

The technology relies on the proven power of cloud technology to combine artificial intelligence with machine learning algorithms to create and deploy “digital fingerprints” using ambient cognitive cyber surveillance to cast a net over EHRs and other hospital data sanctuaries. It exposes user behavior deviations while accessing EHRs and other applications with PHI that humans would miss and can not only augment current defenses against outside hackers and malicious insiders, but also flag problem employees who continually violate cyber security policy.

“Hospitals have been hit hard by data theft,” said Doug Brown, CEO, Black Book Research. “It is time for them to consider new IT security initiatives. Harnessing machine learning artificial intelligence is a smart way to sort through large amounts of data. When you unleash that technology collaboration, combined with existing cloud resources, the security parameters you build for detecting user pattern anomalies will be difficult to defeat.”

While the technology is advanced, the concept is simple. A pattern of user behavior is established and any actions that deviate from that behavior, such as logging in from a new location or accessing a part of the system the user normally doesn’t access are flagged.  Depending on the deviation, the user may be required to provide further authentication to continue or may be forbidden from proceeding until a system administrator can investigate the issue.

The cost of this technology will be positively impacted by the continuing decline in the cost of storage and processing power from cloud computing giants such as Amazon Web Services, Microsoft and Alphabet.

The healthcare data security war can be won, but it will require action and commitment from the industry. In addition to allocating adequate human and monetary resources to information security and training employees on best practices, the industry would do well to implement network surveillance that includes behavior analysis. It is the single best technological defense against the misuse of medical facility systems and the most powerful weapon the healthcare industry has in its war against cyber criminals.

Can Healthcare Ransomware Be Stopped? Yes, It Can!

Posted on May 25, 2016 I Written By

The following is a guest blog post by Steven Marco, CISA, ITIL, HP SA and President of HIPAA One®.
Steven Marco - HIPAA expert
As an Auditor at HIPAA One®, my goal is to dot every “i” and cross every “t” to ensure a comprehensive HIPAA Security Risk Analysis.  The HIPAA One® Security Risk analysis is a tool to guarantee compliance, automate risk calculations and identify high-risk technical, administrative, physical and organizational vulnerabilities.

Recently, I was on-site for a client named “Care Health” (name changed to protect their identity). Care Health had invested in the highest level of our SRA (Security Risk Analysis) to cover all aspects of security and protection from Ransomware, malware, and the proverbial “sophisticated malware.”

The HIPAA One® HIPAA Security Risk Analysis and Compliance Interview process guided Care Health through a series of HIPAA citation-based questions and required users to upload documents to demonstrate compliance.  These questions directly addressed the organization’s security controls in place to protect against ransomware and cyber-threats.  You can see a sample of the citation-driven controls HIPAA One required for malware and malicious software below:

Technical Audit Controls 164.312(b)
HIPAA One® Requirement:  Upload screenshots of the systems configuration page(s) detecting malware network communications or ePHI/PII going out/in.
Client Controls:  End-user education on malware and phishing. Cisco IPS/IPS module active to block critical threats and WebSense Filter for deep-packet web-traffic inspection.

Administrative Protection from Malicious Software 164308(a)(5)(ii)(B)
HIPAA One® Requirement:  Provide a document showing a list of all servers, workstations and other devices with updated AV Software versions.
Client Controls: BitDefender Enterprise deployed on all workstations and laptops.

Administrative Procedures to guard against malicious software 164.308(a)(5)(ii)(B)
HIPAA One® Requirement:  Please upload a list of each server and sample of PC devices containing server name, O/S version, Service pack and the most recent security updates as available by the software vendor.  Verify critical security patches are current.
Client Controls:  Microsoft Security Operations Center combined with an exhausting change-management process to test new patches prior to release.

HIPAA Citation:  Administrative Training program for workers and managers 164.308(a)(5)(i) for the HR Director role.
HIPAA One® Requirement: Please upload a screen capture of the HIPAA training system’s grades for individual employees and detail the training/grading system in notes section.  Go through training and verify it efficiently addresses organization’s Policies and Procedures with real-world threats.
Client Controls:  Training that is due and required before bonuses, pay-raises or schedule to work are awarded.  Workforce and IT Helpdesk are trained to forward any calls regarding suspicious activities to the HIPAA Security Officer (HSO).

HIPAA Security Risk Analysis Tool

Back to the Ransomware attack…One day during the project, two staff members’ in the Billing department were going about their daily tasks, which involved working with shared files in a network-mapped drive (e.g. N: drive).  One of them noticed new files were being spontaneously created and the file icons in the network folder were changing. Being attentive, she noticed one was named ransom.txt.

Acting quickly, she contacted the IT Helpdesk who were trained to triage all security-related service-desk requests immediately to the HIPAA Security Officer(HSO).   The HSO logged-into the N: shared drive and found Care Health files were slowly being encrypted!

How do you stop a Ransomware attack?
The Security officer ran Bitdefender full-scans on the Billing department computers and found nothing.  He then installed and ran Windows Defender, which has the most current malicious software removal utilities on Server 2012 and found Tescrypt.  Installing Windows Defender on the two desktops not only detected this, but also removed it.

This Ransomware variant had somehow infected the system and was encrypting these files.  The quick-acting team at Care Health recognized the attack and stopped the Tescrypt variant before patient data were compromised.  Backups were used to restore the few-dozen encrypted files on the network-drive. It was a close call, but Care Health was ready and the Crisis Averted.

Upon a configuration review of all of Care Health’s security appliances, WebSense had been configured to allow “zero-reputation” websites through.  Zero-reputation websites are new sites without a known reputation and are commonly used by hackers to send these types of attacks. At Care Health, the Ransomware apparently came from a valid website with an infected banner ad from a zero-reputation source. The banner ad was configured to trigger a client-browser download prior to the user being allowed to see the valid web page.  This forced visitors to this website to download the executable virus from the banner-ad and unknowingly installing the Ransomware on their local computer.  When downloaded, the Ransomware would start encrypting files in high-lettered network-drives first.

Lesson Learned
Ransomware is here to stay and attacks are rising.  Healthcare organizations need to have policies and procedures in place to prevent these attacks and a comprehensive user training and awareness program.  The HIPAA One® software is one of the most secure ways to implement a HIPAA Security Compliance Program.  But a risk analysis is only one step… Ultimately, organizations must build top line end-user awareness and training programs. So like at Care Health, the employees know to quickly report suspicious activities to the designated security officer to defend against Ransomware, Phishing and “sophisticated malware attacks”.

To learn more about stopping Malware and using HIPAA One® as your HIPAA Security Risk Analysis accelerator, click to learn more, or call us a 801-770-1199.

HIPAA One® is a proud sponsor of EMR and HIPAA.

10 Health IT Security Questions Every Healthcare CIO Must Answer

Posted on April 19, 2016 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.

Logicalis recently sent out 10 Security Questions Every CIO Must Be Able to Answer. Here’s their list:

  1. If you knew that your company was going to be breached tomorrow, what would you do differently today?
  2. Has your company ever been breached? How do you know?
  3. What assets am I protecting, what am I protecting them from (i.e., theft, destruction, compromise), and who am I protecting them from (i.e. cybercriminals or even insiders)?
  4. What damage will we sustain if we are breached (i.e., financial loss, reputation, regulatory fines, loss of competitive advantage)?
  5. Have you moved beyond an “inside vs. outside” perimeter-based approach to information security?
  6. Does your IT security implementation match your business-centric security policies? Does it rely on written policies, technical controls or both?
  7. What is your security strategy for IoT (also known as “the Internet of threat”)?
  8. What is your security strategy for “anywhere, anytime, any device” mobility?
  9. Do you have an incident response plan in place?
  10. What is your remediation process? Can you recover lost data and prevent a similar attack from happening again?

Given the incredible rise in hospitals being breached or held ransom, it’s no surprise that this is one of the hottest topics in healthcare. No doubt many a hospital CIO has had sleepless nights thanks to these challenges. If you’re a CIO that has been sleeping well at night, I’m afraid for your organization.

The good news is that I think most healthcare organizations are taking these threats seriously. Many would now be able to answer the questions listed above. Although, I imagine some of them need some work. Maybe that’s the key lesson to all of this. There’s no silver bullet solution. Security is an ongoing process and has to be built into the culture of an organization. There’s always new threats and new software being implemented that needs to be protected.

With that said, health IT leaders need to sometimes shake things up in their organization too. A culture of security is an incredible starting point. However, there’s nothing that focuses an organization more than for a breach to occur. The hyper focus that occurs is incredible to watch. If I was a health IT leader, I’d consider staging a mock breach and see what happens. It will likely open your eyes to some poor processes and some vulnerabilities you’d missed.

This Time, It’s Personal: Virus Hits My Local Hospital

Posted on March 30, 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 about two weeks, I am scheduled to have a cardiac ablation to address a long-standing arrhythmia. I was feeling pretty good about this — after all, the procedure is safe at my age and is known to have a very high success rate — until I scanned my Twitter feed yesterday.

It was then that I found out that what was probably a ransomware virus had forced a medical data shutdown at Washington, D.C.-based MedStar Health. And while the community hospital where my procedure will be done is not part of the MedStar network, the cardiac electrophysiologist who will perform the ablation is affiliated with the chain.

During my pre-procedure visit with the doctor, a very pleasant guy who made me feel very safe, we devolved to talking shop about EMR issues after the clinical discussion was over. At the time he shared that his practice ran on GE Centricity which, he understandably complained, was not interoperable with the Epic system at one community chain, MedStar’s enterprise system or even the imaging platforms he uses. Under those circumstances, it’s hard to imagine that my data was affected by this breach. But as you can imagine, I still wonder what’s up.

While there’s been no official public statement saying this virus was part of a ransomware attack, some form of virus has definitely wreaked havoc at MedStar, according to a report by the Washington Post. (As a side note, it’s worth pointing out that if this is a ransomware attack, health system officials have done an admirable job of keeping the amount demanded for data return out of the press. However, some users have commented about ransomware on their individual computers.)

As the news report notes, MedStar has soldiered on in the face of the attack, keeping all of its clinical facilities open. However, a hospital spokesperson told the newspaper that the chain has decided to take down all system interfaces to prevent the spread of the virus. And as has happened with other hospital ransomware incursions, staffers have had to revert to using paper-based records.

And here’s where it might affect me personally. Even though my procedure is being done at a non-MedStar hospital, it’s possible that the virus driven delay in appointments and surgeries will affect my doctor, which could of course affect me.

Meanwhile, imagine how the employees at MedStar facilities feel: “Even the lowest-level staff can’t communicate with anyone. You can’t schedule patients, you can’t access records, you can’t do anything,” an anonymous staffer told the Post. Even if such a breach had little impact on patients, it’s obviously bad for employee morale. And that can’t be good for me either.

Again, it’s possible I’m in the clear, but the fact that the FUD surrounding this episode affects even a trained observer like myself plays right into the virus makers’ hands. Now, so far I haven’t dignified the attack by calling the doctor’s office to ask how it will affect me, but if I keep reading about problems with MedStar systems I’ll have to follow up soon.

Worse, when I’m being anesthetized for the procedure next month, I know I’ll be wondering when the next virus will hit.

Ransomware Crisis Demands Provider Cooperation

Posted on February 22, 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.

A few days ago, the sadly-predictable news broke that a U.S. hospital had been hit with a ransomware attack. Initial reports were that hackers demanded that Hollywood (CA) Presbyterian Medical Center pay $3.4M in bitcoins to regain access to its data. The hospital refused, and began working with paper to meet its patients’ needs. However, it was later reported that the $3.4 million number was wrong and the hospital was only asked to pay $17,000. The hospital chose to pay the ransom and got data access back.  But the mere fact that Hollywood Presbyterian got off relatively easily shouldn’t blind us to the growing ransomware threat, nor the steps we need to take to address this crisis.

Now, before I ramble on about what I think should be done, please bear in mind that I’m an HIT analyst and writer, not a network engineer. So the modest proposal is coming from a non-technical person, but I do believe that it has some merit as an idea. Hopefully readers will continue to improve, debate, and educate us on the merits and challenges of the idea in the comments.

Here’s my proposal. Whereas:

* Hospitals can’t afford to have their data randomly locked any more than airlines can afford to have their engines do so, AND

* Nobody wants to voluntarily create a ransomware market that grows steadily stronger as hospitals pay up, SO

I suggest we find a new way for hospitals to cover each others’ back. The idea would be to make it more or less impossible for hackers to capture all of another hospital’s data.

Here’s where I get hazy, so follow me — and criticize me, please — but what if every hospital had a few sister hospitals which held part of the day’s data backup?  I can see attackers shimmying through every currently available connection at a single institution, but would all five be vulnerable if they only connected in the event a data lockout at hospital A?

Even if such a peer to peer architecture would work, I’m not sure it would be practical. After all, it’s one thing to download an illegal software copy via P2P and quite another to help restore a terabyte or more of data.

Also, it certainly hasn’t escaped me that there are serious competitive concerns involved in setting up such arrangements, though those could certainly be mitigated by the fact that no sister hospital would have a complete data set for Hospital A.

Even if this idea is utter garbage, however, I believe we’ve reached a point where if we’re going to fight ransomeware, some form of deep industry cooperation is necessary. Let’s not wait for patients to be harmed or die due to data lock-out.