Cyber insurance is a rapidly-growing extension of the insurance industry. Data is now an important possession the same way your car and home are. However, insurance companies are having challenges in determining how much to charge and how much coverage that gets you. Luckily, there’s a metric for that.
Most people are relatively aware of the Health Insurance Portability and Accountability Act (HIPAA). It was created to make sure that medical records of patients remain safe, and that the medical providers accessing them are doing their best to ensure that’s the case. When most people think of HIPAA, they often go right to medical providers and hospitals. It’s important to understand that dental providers are also expected to adhere to HIPAA requirements. However, being HIPAA compliant poses challenges for dental providers. Here are some of those challenges, and what dental providers can do to combat them.
Failure to Identify Your Dental Practice as a HIPAA “Covered Entity”
Covered entities are required to follow HIPAA requirements. A dental practice is considered a covered entity if it transmits an electronic claim, payment, etc. to a dental plan or on behalf of a dental practice. It’s very likely that your dental practice is a covered entity and should be considering HIPAA requirements.
Missing Business Associate Agreements (BAAs)
Outside people or entities often have access to patient records and information. If your dental practice works with third parties of this nature, it’s important that you’re keeping tabs on them. Third parties are often root causes of breaches and data exposure. Continuously review your third parties and be sure you have BAAs for them.
Security Policies and Procedures
Well thought out, written plans are needed to ensure that your practice stays in compliance. Your HIPAA compliance policy should clearly state the responsibilities of your office and each staff member in protecting your patients’ private health information. The policy should clearly outline how your office handles and remediates various kinds of security breaches.
Training employees is a critical component to HIPAA compliance, even for dental practices. Once you have your policies and procedures in place, it becomes critical that you train your employees on them. If someone’s job is affected by a change in your HIPAA policies or procedures, provide training on the change within a reasonable time after the change becomes effective. Training employees will limit the risk of breach.
Texting and Email
HIPAA applies to emails and text messages sent to a patient, such as for scheduling or appointment reminders. HIPAA also applies to emails and texts sent to another provider about a referral, with diagnostic images, or to discuss treatment. Here’s the kicker—HIPAA applies when a dentist emails patient records or information from a work email account to a personal email account, even if the dentist is doing so simply to finish up work from home later that evening. While HIPAA doesn’t prohibit using email or text to communicate patient information, it is important it’s done the proper way.
A restaurant is very likely to respond to a Yelp, Facebook or Google review to either appreciate what has been said, or try to take corrective action. Dental practices must be a bit more careful. It’s easy to respond in a way that violates HIPAA rules. Ensure you and your employees understand privacy rules before responding to your practice’s reviews.
As photos or videos are being taken of a patient there is the possibility that other patients may be included inadvertently. These photos and videos are quite often shared through social media and this can compromise those patients’ privacy. In addition, staff members of the practice might be included in the photo or video and this violates their privacy. Be cognizant of what is going on in the background of your images and videos so you do not compromise patient information.
Breaches happen. It can and will happen to anyone at any time. It’s crucial that you understand what you need to report, and when. Covered dental practices must report all breaches of unsecured protected health information to the Office of Civil Rights, as well as to individuals and, in some cases, to the media. The bottom line is, have a plan for what to do in case an incident does occur, because it certainly can.
How can you get a better understanding of these challenges, so you know how to avoid and face them? A security assessment is a great tool to do that. Security assessments helps you identify where your gaps in security are. Once they’ve been identified, you can also use the assessment to develop action plans for improvement, meeting HIPAA regulations and proving to examiners that you have a strong data protection program. While there are many challenges as a dental provider to being HIPAA compliant and safeguarding patient information, getting a security assessment puts you on the fast track to understanding and preventing your patients’ data being compromised.
FISASCORE® is a comprehensive assessment that measures your organization’s information security risk. It was created because of a recognized need in the information security industry for a common language people could use to be on the same page about security. Built on the widely unsterstood credit score scale, FISASCORE measures four different types of controls and give you the score to litmus test and starting point for improvements. Every organization should have a FISASCORE and here is why.
1. FISASCORE is easy to understand.
Information security is a complex discipline with many moving parts, but FISASCORE simplifies the communication about how your information security program is performing. You don’t need to be an information security expert with years of experience to understand what FISASCORE is telling you. One simple number represents your overall risk, and additional indicators show where your most significant risks are.
2. FISASCORE can tell you what everyone else is doing.
Hundreds of organizations have received their FISASCORE and this allows for good, fact-based comparisons. One of the common questions we receive about information security is, “What is everybody else doing?” This question comes from the responsibility for due care/due diligence, liability, and knowing that there’s “protection in the herd.
3. With a FISASCORE, you can track progress.
FISASCORE is a point of reference that should be used to track progress and to determine whether risk is maintained within your tolerance. Your information security program and risks are always getting better or worse; they never stay the same. Questions about progress, regular reporting, and support for maintaining your information security program are all answered through the FISASCORE.
4. FISASCORE is objective.
FISASCORE is maintained by an independent organization that doesn’t do consulting work, and has no other purpose but to provide accurate measurements of information security risk. In addition to organizational objectivity, the score is also objective. FISASCORE is calculated through the measurement of thousands of objective characteristics that take much of the guesswork and opinion out of the equation.
5. FISASCORE is credible.
FISASCORE was developed over the course of more than 15 years through the work of seasoned information security practitioners and is now on its fifth major release. FISASCORE is based on generally well-accepted information security standards. The criteria for measurement are all referenceable to the NIST Cybersecurity Framework (CSF), and its supporting standards: NIST SP 800-53, COBIT, ISO 27001:2013, and CIS CSC.
6. FISASCORE represents risk.
Risk is the combination of vulnerabilities and applicable threats that manifest themselves into the likelihood of something bad happening and the impact if it did. If there is no vulnerability (or weakness) in a control, there is no risk. If there is a vulnerability in a control without an applicable threat, there is also no risk. FISASCORE represents the analysis of hundreds of controls, thousands of vulnerabilities and thousands of threats, resulting in likelihoods and impacts of bad events.
7. FISASCORE is comprehensive.
Fundamental to FISASCORE is our definition of information security: The application of administrative, physical, and technical controls to protect the confidentiality, integrity and availability of information. There are four phases within FISASCORE:
• Phase 1 – Administrative Controls
• Phase 2 – Physical Controls
• Phase 3 – Internal Technical Controls
• Phase 4 – External Technical Controls
All four parts of the information security program must work well together. A weakness in one control can lead to a collapse of all others. The phases are further segmented into sections, and the sections are further segmented into controls. The final FISASCORE report is presented both high level and then digs deep in the details.
8. There is fast-growing community support for FISASCORE.
The partner community behind FISASCORE is critical to its success. Partners works to generate FISASCOREs for their clients, but the partner community is also vital to future improvements and considerations. The partner community participates in further improvements of the methodology, shares critical information, and evangelizes the need for a common information security language (provided by FISASCORE). Our partners include IT service companies, CPA firms, insurance brokers and security consulting companies.
9. FISASCORE is an indicator of future losses.
As FISASCORE continues to evolve, we get closer to understanding the true losses behind information security incidents and breaches. FISASCORE provides the framework for predicting future information security losses accurately, using the best information available. Today FISASCORE is tied to research conducted by the Ponemon Institute for loss data.
10. FISASCORE is a competitive advantage.
Information security as a competitive advantage? Yes, absolutely! FISASCORE is a representation of the efforts you’ve put into information security and it’s a demonstration that you know where your most significant information security risks are. Armed with this information, you can make an objective case to your customers that you take information security seriously, backed by experienced information security experts, a community of partners, and a clean methodology. Don’t forget the fact that you can now invest your information security dollars where they will have the greatest benefit.
Douglas County Hospital is a system of healthcare providers that includes Heartland Orthopedic Specialists, Alexandria Clinic and Osakis Clinic. This 127-bed, non-profit regional hospital and clinics located in Alexandria, MN includes 875 staff and 72 physicians and advanced practice professionals providing integrated health care services to the patients, families and communities they serve.
The hospital is heavily focused on customer care, and because of this, saw a need to keep the organization’s patient data as safe as possible. Its leadership understood that compliance is only a small part of risk management and that it needed to expand its thinking beyond the ordinary security measures. Heating and cooling systems, outside foliage and camera placements were just a few potential vulnerabilities the hospital was looking to measure vulnerabilities on.
So, Douglas County Hospital looked to SecurityStudio®.
SecurityStudio® was vital in helping the hospital mature its information security program. It provided an intensive independent review of the hospital’s security practices. To do so, it used the FISASCORE® assessment, a security rating system that measures internal, external, administrative and physical security controls. This assessment was the crucial first step in improving the hospital’s security program, as it indicated strengths, weaknesses and threats that could help determine where the focuses for improvement should lie.
“Our information security program and policies should be based on an independent and unbiased standard. This assessment is helpful as it gives us a foundation on which to mature our program, develop new policies and rework current practices,” Director of Information Security, Joyce Beck said.
“We wanted to understand our security position and its effectiveness. After the assessment we learned that strengthening logical segmentation protocols via restrictive VLAN would protect our overall network from unauthorized access in a more effective way. Systems such as heating, cooling and camera control were given limited access and could only communicate on their assigned VLAN networks,” IT Lead Ryan Engelbrecht added.
The implementation of the additional protocols through the assessment added an additional layer of security to the hospital’s overall security. On top of this, it shifted their focus from reactionary thinking to a proactive mindset with a systematic handling of their known vulnerabilities, and it guided the hospital on recommended lifecycles for its hardware and software.
“Asset management was one of the tools we utilized but not to its fullest potential. Improved documentation was implemented and additional methods for auditing and ensuring the necessary follow through were added. The assessment gave us an approach that was modest and a directive to keep it simple, by starting at square one and building this plan from the ground up. This made the process of managing our hardware less overwhelming and cumbersome,” Engelbrecht said.
The FISASCORE® security assessment not only pinpointed vulnerabilities for immediate improvement but also provided a roadmap for enhancing the overall security posture of Douglas County Hospital. Overall, this open, collaborative and mentoring approach is what made the difference to improving the hospital’s security position now and into the future.