Group: GTR ver M Grace Chen Taru Singhal Robert Szymanek Michael Parker

Security of eHealth InformationHIPAA Compliance at HRA

Identify the Problem Compliance/Risk Storage Options Transmission Options Feasibility Analysis Final Recommendation

Agenda

Deficiencies in the process of storage/backup ◦ Is the current data stored? ◦ Is there a secure backup currently performed?◦ Is current data encrypted?◦ Currently how is data archived?

Deficiencies in the process of transmission ◦ What is the best way to transmit data?◦ What Is the best encryption◦ Is E-mail safe? ftp/sftp?

Identify the Problem

Social Security numbers Home addresses and telephone numbers Personal and family health history Bank accounts and credit card numbers

Types of Sensitive Information

The HIPAA Privacy Rule applies to:◦ Health plans◦ Healthcare clearinghouses, part of an HIO◦ Healthcare providers that conduct covered

transactions

Healthcare Information Organization (HIO) performs certain functions or activities which require access to PHI

Healthcare clearinghouses collect data such as PHI and data-mine them

Why Compliance?

Federal Penalties◦ The U.S. Department of Health & Human Services has the

authority to impose penalties of $100 to $50,000 or more per violation.

Criminal Penalties◦ The U.S. Department of Justice has the right to fine

organizations and individuals who intentionally violate standards. The penalties range from $50,000 to $250,000, with various jail sentence lengths, depending on the offense.

Risk of Non-Compliance

Encrypt data on servers and email Restrict use of file sharing applications and

portable devices Provide protection against malware and

attacks Use comprehensive security policies Log data points for compliance audits

Protect the organization!

Storage of Protected Health Information

Opt 1: Data Center/Iron MountainOpt 2: Citrix Solution/Iron Mountain

SAN/Servers - $160,000 Cisco - $24,000 VMware/Failover - $26,000 Applications (VeriSign, sftp) - $10,500 Contractors - $9,400 Total - $229,900

Opt 1: Data Center Infrastructure

Citrix Access Gateway protects data using standards-based encryption technologies (SSL/TLS).

Secure remote access. Leading SSL VPN performance and

scalability. Protect intellectual property with corporate

policies. Lets users work from anywhere.

Opt 2: Citrix Solution

Citrix Solution Estimate

Data Center (1,000 users) - $229,900 Same expense as for both solutions.

Rapid recovery Extremely high security Reduce risk of server data loss and

downtime Continuous backup Protection of open files and databases Flexible retention periods Access when and where you want it

http://www.ironmountain.com/health-information/health-server-backup.html

Opt 1/2: Iron Mountain Services

$2.15 per GB per month HIPAA Retention Period is 7 years

Opt 1/2: Iron Mountain Expenses

1 TB 2 TB 2.5 TB 3 TB

Price/GB $ 2.15 $ 2.15 $ 2.15 $ 2.15

Price/Mo $ 2,150.00 $ 4,300.00 $ 5,375.00 $ 6,450.00

Price/Yr $ 25,800.00 $ 51,600.00 $ 64,500.00 $ 77,400.00

Extended (3 yr) $ 77,400.00 $ 154,800.00 $ 193,500.00 $ 232,200.00

Operating expense, non-capital

Transmission of Protected Health Information

Secure FTP can be used as a technical mechanism, protecting data in motion within a distributed healthcare system.

Secure Shell password controls file access. Secure Shell encryption controls confidentiality of the

information. Server Event logs facilitates a security audit.

Data Transmission - Secure FTP

The primary rule within HIPAA that affects e-mail is the Security Rule.

Many encryption technologies require the user to become familiar with the use of plug-ins and other specialized “client-side” encryption software

Another issue faced by organizations is a lack of technological standards

The solution to each of these issues is to move the encryption responsibility from the individual user to a specialized server.

Data Transmission - Secure Email

The team is ready to implement a multi-layered system using the Data Center storage and Iron Mountain

Secure transmission using secure ftp and secure email for transmission of Protected Health Information.

Provision sufficient resources to implement a Citrix solution when needed, plan for FY 2012 or FY 2013.

Solution Implementation

New Deployments (No teardown)◦ Storage/backup◦ Secure Email◦ Secure FTP

Maintenance Considerations for IT staff◦ Ensuring complete backups (Iron Mountain)◦ Enforcing Data Center SLA standards◦ Checking secure local storage◦ Maintaining VeriSign certificates for email and FTP

Processes invisible to end users!

Feasibility Analysis

Iron Mountain (2.5 TB) - $193,500 Iron Mountain is an annual operating expense at

$64,500/year Operating costs affect Income Statement

Data Center (Infrastructure required) - $229,900 A capital expense at depreciates at $45,980/year over 5 years Capital expenses affect the Balance Sheet Maintenance approx 10% of purchase price, capitalized

Total - $412,900

The SolutionData Center – Infrastructure

Iron Mountain – Secure Backup

Thank You

Questions?