Welcome to EMR and HIPAA

I think that Google is confused about my blog. I don’t think it knows if it should categorize me as an EMR blog or as a HIPAA blog. In fact, sometimes it even thinks I’m an EHR blog which is perfectly fine by me. Right now I think that Google thinks that I’m a HIPAA blog, but quite honestly I think I’d rather be an EMR blog. Sure, I cover HIPAA and some of the various HIPAA related news on here. In fact, it’s kind of hard to cover EMR and not cover certain aspects of HIPAA. However, I think at the end of the day I’m more interested in EMR and EHR and I really don’t care about HIPAA. It’s a necessary evil.

I guess I’ll have to focus more of my posts on EMR and EHR and stop using that naughty H word since Google seems to like to classify with that H word when I want to show up for EMR and EHR. At the end of the day it doesn’t really matter too much, but as a tech person I always think it’s fun to see what the Google bots see in my content. It’s kind of a way to justify myself that the bots are happy and classify me as an authority on a subject.

Are you listening Google bots? I’m an EHR and EMR blog. Make sure I make it to the top of searches related to EMR and EHR. That’s really where I’m meant to be. I can feel it in my bones. Well, at least that’s who I want to be.

This information is a little bit dated, but it was sitting in my draft posts and I think that it’s still very relevant to those interested in HIPAA compliance. Computer World posted an article about Atlanta’s Piedmont hospital being the first organization to have a HIPAA audit by the HHS.

In the report they identified 42 questions that HHS reportedly asked Piedmont hospital during the HIPAA audit. Regardless of how accurate this is, I think that it’s interesting for all those in the healthcare industry to evaluate these questions and how they apply in their environment.

Here’s the list of questions:

1. Establishing and terminating users’ access to systems housing electronic patient health information (ePHI).
2. Emergency access to electronic information systems.
3. Inactive computer sessions (periods of inactivity).
4. Recording and examining activity in information systems that contain or use ePHI.
5. Risk assessments and analyses of relevant information systems that house or process ePHI data.
6. Employee violations (sanctions).
7. Electronically transmitting ePHI.
8. Preventing, detecting, containing and correcting security violations (incident reports).
9. Regularly reviewing records of information system activity, such as audit logs, access reports and security incident tracking reports.
10. Creating, documenting and reviewing exception reports or logs. Please provide a list of examples of security violation logging and monitoring.
11. Monitoring systems and the network, including a listing of all network perimeter devices, i.e. firewalls and routers.
12. Physical access to electronic information systems and the facility in which they are housed.
13. Establishing security access controls; (what types of security access controls are currently implemented or installed in hospitals’ databases that house ePHI data?).
14. Remote access activity i.e. network infrastructure, platform, access servers, authentication, and encryption software.
15. Internet usage.
16. Wireless security (transmission and usage).
17. Firewalls, routers and switches.
18. Maintenance and repairs of hardware, walls, doors, and locks in sensitive areas.
19. Terminating an electronic session and encrypting and decrypting ePHI.
20. Transmitting ePHI.
21. Password and server configurations.
22. Antivirus software.
23. Network remote access.
24. Computer patch management.

HHS also had a slew of other requests:

1. Please provide a list of all information systems that house ePHI data, as well as network diagrams, including all hardware and software that are used to collect, store, process or transmit ePHI.
2. Please provide a list of terminated employees.
3. Please provide a list of all new hires.
4. Please provide a list of encryption mechanisms use for ePHI.
5. Please provide a list of authentication methods used to identify users authorized to access ePHI.
6. Please provide a list of outsourced individuals and contractors with access to ePHI data, if applicable. Please include a copy of the contract for these individuals.
7. Please provide a list of transmission methods used to transmit ePHI over an electronic communications network.
8. Please provide organizational charts that include names and titles for the management information system and information system security departments.
9. Please provide entity wide security program plans (e.g System Security Plan).
10. Please provide a list of all users with access to ePHI data. Please identify each user’s access rights and privileges.
11. Please provide a list of systems administrators, backup operators and users.
12. Please include a list of antivirus servers, installed, including their versions.
13. Please provide a list of software used to manage and control access to the Internet.
14. Please provide the antivirus software used for desktop and other devices, including their versions.
15. Please provide a list of users with remote access capabilities.
16. Please provide a list of database security requirements and settings.
17. Please provide a list of all Primary Domain Controllers (PDC) and servers (including Unix, Apple, Linux and Windows). Please identify whether these servers are used for processing, maintaining, updating, and sorting ePHI.
18. Please provide a list of authentication approaches used to verify a person has been authorized for specific access privileges to information and information systems.

Since most of my interest is in ambulatory care, I wonder if an audit would be this extensive for ambulatory care. Talk about putting a company out of business. This would be an extensive report for a hospital but could be really detrimental to a small doctor’s office. Still interesting to think about.

I expect that no one is fully compliant with this list. Of course, that raises the question of what’s full compliance, but we’ll save that topic for another day.