Perfecting cybersecurity through better training and testing

Various types of training and testing of health care professionals and staff can be used by health care entities to perfect their cybersecurity programs, according to a Health Care Compliance Association (HCCA) webinar presented by Steve Snyder of Smith Moore Leatherwood, LLP.

Snyder believes that perfecting cybersecurity training and testing is made especially challenging due to the uniqueness of the cybersecurity threat. Snyder listed the primary factors making cybersecurity unique, including:

  • the people trying to penetrate are adversarial and usually off-shore;
  • cyberattacks are evolving rapidly, with attacks designed to respond to new defenses;
  • cybersecurity involves highly technical concepts, which make staff hesitant to embrace safeguards; and
  • cybersecurity is outside the core competency for most of the staff to be trained and tested.

Training

Snyder believes that cybersecurity training must take a long term view, be about learning and reminding, have the objective of conditioning behavior, and must evolve over time as circumstances and threats change.

Opportunities for training, according to Snyder, could be when new job functions are created, when introducing new procedures, or when reinforcing integral work functions. He listed the possible training scenarios and their pros and cons as:

  • External programs offered by third parties. These programs offer specialized knowledge and instruction but can be costly, rely on the competency of others, and may suffer from the lack of familiarity of the third-party with the organization.
  • Internal learning management systems (LMS). These internal systems, relying on online or classroom training, can develop custom content and make tracking compliance easy. However, they require internal expertise and can create a record of noncompliance for government investigators.
  • This method can be particularly effective for conveying best practices to staff members in a new role. However, it requires competent mentors and is not ideal for new and evolving issues that the mentor is unfamiliar with.
  • Passive measures (e-mail reminders, etc.). This method is easy, cheap, and is agile enough to address emerging issues. However, it is easy for staff to ignore and therefore it is hard to access effectiveness.
  • Training tips. Snyder’s cybersecurity training tips included the following:
  • Start with objectives (such as increasing reporting of possible cyber incidents) and work back to prevention methods.
  • Try to find objective metrics (such as the rate of reporting vs. known incidents).
  • Make it digestible by staff (we live in a sound bite society).
  • Show a tangible purpose (clicks = malware = detriment to business).
  • Use varying approaches as people learn differently.
  • Make it interesting by using gamification, simulations, scoring, ranking, competitions, etc.

Testing

Snyder believes that testing should be focused on existing knowledge and established procedures. He favors a testing program with a narrow focus and reoccurring elements. The goals of testing, according to Snyder, should insure that cybersecurity procedures are known and understood, are effective, guarantee compliance, and identify gaps in policies and procedures.

Snyder listed several types of cybersecurity testing:

  • Penetration testing (looking for breach of security from the outside).
  • Vulnerability testing from the inside (looking for known bugs, unpatched software, or legacy systems that can be exploited).
  • Simulated testing (using drills and tabletop exercises).
  • Pop quizzes (discrete staff testing).
  • Final comprehensive exams.

Final takeaway

Snyder wrapped up his presentation by stressing that in training and testing for cybersecurity, and organization should: (1) be contemplative in designing their programs, (2) use a mix of internal and external resources, and (3) assess and revisit the programs often.

Kusserow on Compliance: The OIG on Health IT security

Many are not aware of the fact that the HHS OIG boasts having an A-class team that focuses on IT controls and engages in what they refer to as penetration testing or “hacking” into IT systems and networks. With 100 million health care records already compromised and medical records serving as a top target for hackers, healthcare related cybersecurity has become a high priority for the OIG. Health IT offers some unique challenges, in that health records are for a lifetime, whereas credit cards may have a shelf life, if they’re compromised, of just a day or two. This makes them very valuable for criminals that can often realize 60 times more than what a stolen credit card can yield on the dark web. Compromised health information could have wide-ranging consequences, including affecting credit and even someone filing a false tax return with the information. In addition to people’s personal information, there is concern about health care provider and managed care proprietary information.

The OIG IT audits begin with setting an audit objective, which varies according to what they are trying to accomplish. The OIG desires to provide transparent and objective assessments of the security posture of the systems within HHS and those that receive funding from HHS. The OIG engages in penetration testing, as a means to help strengthen IT vulnerabilities. By engaging in penetration testing or “hacking into” IT networks, the OIG is able to provide chief information officers, and sometimes CFOs, with information regarding particular vulnerabilities. Among the common testing of IT systems is determining whether passwords are being changed periodically.  The OIG stated guiding philosophy is that “what gets checked gets done.” By identifying vulnerabilities, they draw management attention to addressing them and raising their awareness to cybersecurity.

The OIG wants to ensure that funds for cybersecurity, and ultimate for technology, are being used judiciously, and overall the OIG is working every day to protect sensitive personal and proprietary data. The OIG is using its resources to enhance awareness around cybersecurity.  The OIG focuses much of its resources on IT controls for the Medicare enrollment database; however the OIG does not confine its work to the Medicare and Medicaid space. The OIG is also looking at IT security at NIH, Indian health hospitals throughout the country, and FDA information on drugs and medical devices. The OIG typically addresses reports to senior level personnel, such as the CEO and Chief Information Officer, and often addresses reports to state administrators for Medicare and Medicaid.

Richard P. Kusserow served as DHHS Inspector General for 11 years. He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.

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Copyright © 2017 Strategic Management Services, LLC. Published with permission.

House committee takes interest in ‘NotPetya’ malware attack fallout

House Energy and Commerce Committee leaders are concerned that a malware attack from late June 2017, known as “Petya” or “NotPetya,” may have lingering effects on Merck & Co, Inc. The leaders sent letters to Merck’s CEO and HHS Secretary Price expressing this concern and requesting additional information about the attack and the effects on the company.

NotPetya

The malware infection began on June 27, 2017, and spread across the world, infecting businesses from a variety of sectors. At the time of the attack, the extent of Merck’s vulnerability was not precisely known, although an employee reported that they were told to stop working and some computers appeared to be wiped and that all U.S. offices were affected by the attack. The committee letters referred to information provided in Merck’s second-quarter 2017 financial outlook, which stated that packing operations were mostly restored, formulation operations were partially restored, and active pharmaceutical ingredient operations were partially restored but bulk product was not yet being produced.

Patient risk

The committee’s interest in the matter stemmed from concern that patients may have been negatively impacted by manufacturing disruption. Although evidence of such risk was not present, the committee pointed to an announcement from the Centers for Disease Control and Prevention (CDC) that certain formulations of Merck’s Hepatitis B vaccine would not be available. The committee requested that Merck provide a formal briefing to the committee on the initial infection and Merck’s steps to recover and resume manufacturing by October 4, 2017. The committee also requested an HHS briefing on the agency’s steps to understand and respond to the situation as well as plans for addressing drug shortages or other consequences stemming from cyberattacks.

IT experts say foreign actors, human error biggest threats to health record security

Foreign hackers and human error are two of the most significant threats to protected health information (PHI) and other health records that providers and health care entities must prepare for, according to four information technology experts speaking at a conference sponsored by Becker’s Hospital Review. They all agreed that breaches and cyberattacks will continue, so health care institutions must be diligent about security systems, audits, training, insurance, and adequately responding to breaches to mitigate punishment and quickly recovery from an attack..

Weakest link 

Aaron Miri, chief information officer for Imprivita, and Michael Leonard, director at Commvault, both noted that regardless of the tools and systems put in place to ward off breaches, malware, ransomware, and other cybersecurity threats, people will always be the weakest link. Leonard noted that when it comes to an institution’s cybersecurity program, “people training has to be continuous and repetitive.”

Katherine Downing, senior director at the American Health Information Management Association (AHIMA), highlighted one type of “insider threat”—physicians who do work arounds that bypass the security features of electronic health record (EHR) systems (like texting PHI about patients to each other). Although David Miller, CEO of HCCIO Consulting, LLC, was blunter when asked what the biggest threat was to PHI and other health records—”Russia and China.”

Jurisdictions

Miri noted that providers must deal with a “wide disparity of laws” regarding the security and privacy of health information, not just federal and state laws, but, starting in May 2018, the General Data Protection Regulation (GDPR) issued by the European Union. The GDPR replaces a framework of different information security measures that mainly affected just European companies with a national network and information security strategy that will impact American life sciences and healthcare entities that collect and/or use any data concerning health, genetic data, or other types of protected health information (PHI).

Audits

Miller expressed amazement at how many health care institutions have not had a HIPAA audit in the previous two years. The HHS Office for Civil Rights (OCR) reviews organizations’ compliance with the HIPAA Privacy, Security, and Breach Notification Rules and looks for documentary proof that entities have conducted risk assessments and created and implemented policies and procedures governing areas including the shielding of PHI. Miller noted that providers must continually educate and re-educate staff on policies related to HIPAA. But he added that providers can also “take advantage of a breach situation to talk to senior management to increase security measures.”

Record retention

In addition to protecting PHI, health care entities have to make decisions about destroying records after record retention periods have ended. Katherine Downing, senior director at the American Health Information Management Association (AHIMA), noted that entities “can’t keep everything forever.” Downing noted that health care entities already have the expense of saving, backing up, and securing required health records; doing the same for older records that no longer have to be retained is just an added expense.

In the end, Miri noted that these are the questions that health care entities have to ask: What are they willing to spend to avoid a breach? What are they willing to risk regarding their reputations?