Re: Questions in regard to Security/Privacy

2003-02-27 Thread Doug Webb



Richard,
The first question is: Is what is being transmitted Protected 
Healthcare Information? If not all the rest is moot. If what is 
being transmitted is strictly the financial data (This merchant charged this 
person this much), it probably isn't PHI, but just money.

If it is you must do a risk-of exposure analysis.
First, the receiving system must be capable of properly 
protecting any PHI it receives.

Terminal-to-Private Network is probably adequately 
secured. In this case, you may decide that encryption is just wasting 
resources.

Going via the Internet will probably need some kind of 
end-to-end encryption to be adequately secure, since the Internet is inherently 
a broadcast to every computer connected to the net, received by anyone who wants 
to listen.

Make your decisions and document them.

The opinions expressed here are my own and not necessarily the opinion of 
LCMH.

Douglas M. WebbComputer System EngineerLittle Company of Mary 
Hospital  Health Care Centers[EMAIL PROTECTED]

"This electronic message may contain information that is confidential 
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  - Original Message - 
  From: 
  Richard 
  Smith 
  To: WEDI SNIP Privacy Workgroup List 
  
  Sent: Thursday, February 27, 2003 11:52 
  AM
  Subject: Questions in regard to 
  Security/Privacy
  I would like to know how the privacy  
  security act under HIPAA will impact ourcurrent systems today? I support 
  POS card/swipe machines that dialup (via anasync/sync modem) over the 
  public telephone system into a server that isconnected to a private 
  network. These machines (terminals) are located throughout the USA in 
  Provider offices, clinics and hospitals. The dialup protocol(VISA) is the 
  same protocol that the financial processors use today doingcredit/debit 
  transactions. Are there any issues that I need to be concernedabout from 
  the terminal point of view?The second part of my question, I would 
  like to know how the privacy  securityact under HIPAA will impact POS 
  card/swipe machines that dialup (via anasync/sync modem) over the public 
  telephone system into a ISP that is connectedto the Internet. These 
  machines (terminals) are located through out the USA inProvider offices, 
  clinics and hospitals. The dialup protocol will be either VISAor PPP 
  (Point-to Point). Are there any issues that I need to be concerned 
  aboutfrom the terminal point of view?---The WEDI SNIP listserv 
  to which you are subscribed is not moderated. The discussions on this listserv 
  therefore represent the views of the individual participants, and do not 
  necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. 
  If you wish to receive an official opinion, post your question to the WEDI 
  SNIP Issues Database at http://snip.wedi.org/tracking/. 
  These listservs should not be used for commercial marketing purposes or 
  discussion of specific vendor products and services. They also are not 
  intended to be used as a forum for personal disagreements or unprofessional 
  communication at any time.You are currently subscribed to wedi-privacy 
  as: [EMAIL PROTECTED]To unsubscribe from 
  this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank 
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  you need to unsubscribe but your current email address is not the same as the 
  address subscribed to the list, please use the Subscribe/Unsubscribe form at 
  http://subscribe.wedi.org
---
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RE: Questions in regard to Security/Privacy

2003-02-27 Thread Catherine Lohmeier
I don't see these POS terminals being affected by HIPAA if in fact
they are doing a financial transaction...ie patient is making a
payment for services rendered(paying the co-pay with a credit card).

Now, there is a network of POS terminals that do eligibility checks
and referrals etc..these terminals are conducting transactions for
which a standard has been defined and are therefore subject to the
HIPAA TCS rule.  The use of these POS terminals qualify the provider
as a Covered Entity which in turn makes the provider subject to the
Privacy and Security Rule.

Any other opinions or observations?

CL
 Original Message 
From: [EMAIL PROTECTED]
To: [EMAIL PROTECTED]
Subject: RE: Questions in regard to Security/Privacy
Date: Thu, 27 Feb 2003 09:52:59 -0800

I would like to know how the privacy  security act under HIPAA will
impact our
current systems today? I support POS card/swipe machines that dialup
(via an
async/sync modem) over the public telephone system into a server that
is
connected to a private network. These machines (terminals) are
located through
out the USA in Provider offices, clinics and hospitals. The dialup
protocol
(VISA) is the same protocol that the financial processors use today
doing
credit/debit transactions. Are there any issues that I need to be
concerned
about from the terminal point of view?

The second part of my question, I would like to know how the privacy
 security
act under HIPAA will impact POS card/swipe machines that dialup (via
an
async/sync modem) over the public telephone system into a ISP that is
connected
to the Internet.  These machines (terminals) are located through out
the USA in
Provider offices, clinics and hospitals. The dialup protocol will be
either VISA
or PPP (Point-to Point). Are there any issues that I need to be
concerned about
from the terminal point of view?

---
The WEDI SNIP listserv to which you are subscribed is not moderated.
The discussions on this listserv therefore represent the views of the
individual participants, and do not necessarily represent the views
of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive
an official opinion, post your question to the WEDI SNIP Issues
Database at http://snip.wedi.org/tracking/.   These listservs should
not be used for commercial marketing purposes or discussion of
specific vendor products and services.  They also are not intended to
be used as a forum for personal disagreements or unprofessional
communication at any time.

You are currently subscribed to wedi-privacy as:
[EMAIL PROTECTED]
To unsubscribe from this list, go to the Subscribe/Unsubscribe form
at http://subscribe.wedi.org or send a blank email to
[EMAIL PROTECTED]
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Subscribe/Unsubscribe form at http://subscribe.wedi.org

Catherine Lohmeier
Sr. Business Consultant
PCI: e-commerce for healthcare
ph. 402-304-1918
www.hipaasurvival.com


---
The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions 
on this listserv therefore represent the views of the individual participants, and do 
not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If 
you wish to receive an official opinion, post your question to the WEDI SNIP Issues 
Database at http://snip.wedi.org/tracking/.   These listservs should not be used for 
commercial marketing purposes or discussion of specific vendor products and services.  
They also are not intended to be used as a forum for personal disagreements or 
unprofessional communication at any time.

You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED]
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Re: Questions in regard to Security/Privacy

2003-02-27 Thread Doug Webb



Catherine,
Just a clarification. These non-financial POS terminals would 
have to use standard transactions (such as 270/271, 278, etc.) to do their job 
when a standard is available.

The opinions expressed here are my own and not necessarily the opinion of 
LCMH.

Douglas M. WebbComputer System EngineerLittle Company of Mary 
Hospital  Health Care Centers[EMAIL PROTECTED]

"This electronic message may contain information that is confidential 
and/or legally privileged. It is intended only for the use of the individual(s) 
and entity(s) named as recipients in the message. If you are not an 
intended recipient of the message, please notify the sender immediately, 
delete the material from any computer, do not deliver, distribute, or copy this 
message, and do not disclose its contents or take action in reliance on the 
information it contains. Thank you."



  - Original Message - 
  From: 
  Catherine Lohmeier 
  To: WEDI SNIP Privacy Workgroup List 
  
  Cc: [EMAIL PROTECTED] 
  
  Sent: Thursday, February 27, 2003 03:07 
  PM
  Subject: RE: Questions in regard to 
  Security/Privacy
  I don't see these POS terminals being affected by HIPAA if in 
  factthey are doing a financial transaction...ie patient is making 
  apayment for services rendered(paying the co-pay with a credit 
  card).Now, there is a network of POS terminals that do eligibility 
  checksand referrals etc..these terminals are conducting transactions 
  forwhich a standard has been defined and are therefore subject to 
  theHIPAA TCS rule. The use of these POS terminals qualify the 
  provideras a Covered Entity which in turn makes the provider subject to 
  thePrivacy and Security Rule.Any other opinions or 
  observations?CL Original Message From: [EMAIL PROTECTED]To: [EMAIL PROTECTED]Subject: 
  RE: Questions in regard to Security/PrivacyDate: Thu, 27 Feb 2003 09:52:59 
  -0800I would like to know how the privacy  security act under 
  HIPAA willimpact ourcurrent systems today? I support POS 
  card/swipe machines that dialup(via anasync/sync modem) over 
  the public telephone system into a server thatisconnected to a 
  private network. These machines (terminals) arelocated 
  throughout the USA in Provider offices, clinics and hospitals. The 
  dialupprotocol(VISA) is the same protocol that the financial 
  processors use todaydoingcredit/debit transactions. Are there 
  any issues that I need to beconcernedabout from the terminal 
  point of view?The second part of my question, I would like to 
  know how the privacy securityact under HIPAA will impact 
  POS card/swipe machines that dialup (viaanasync/sync modem) 
  over the public telephone system into a ISP that isconnectedto 
  the Internet. These machines (terminals) are located through 
  outthe USA inProvider offices, clinics and hospitals. The 
  dialup protocol will beeither VISAor PPP (Point-to Point). Are 
  there any issues that I need to beconcerned aboutfrom the 
  terminal point of view?---The WEDI SNIP listserv to 
  which you are subscribed is not moderated.The discussions on this 
  listserv therefore represent the views of theindividual participants, 
  and do not necessarily represent the viewsof the WEDI Board of 
  Directors nor WEDI SNIP. If you wish to receivean official opinion, 
  post your question to the WEDI SNIP IssuesDatabase at http://snip.wedi.org/tracking/. 
  These listservs shouldnot be used for commercial marketing purposes or 
  discussion ofspecific vendor products and services. They also 
  are not intended tobe used as a forum for personal disagreements or 
  unprofessionalcommunication at any time.You are 
  currently subscribed to wedi-privacy 
  as:[EMAIL PROTECTED]To unsubscribe from this 
  list, go to the Subscribe/Unsubscribe format http://subscribe.wedi.org or send a blank 
  email to[EMAIL PROTECTED]If you need 
  to unsubscribe but your current email address is not thesame as the 
  address subscribed to the list, please use theSubscribe/Unsubscribe 
  form at http://subscribe.wedi.orgCatherine 
  LohmeierSr. Business ConsultantPCI: e-commerce for healthcareph. 
  402-304-1918www.hipaasurvival.com---The 
  WEDI SNIP listserv to which you are subscribed is not moderated. The 
  discussions on this listserv therefore represent the views of the individual 
  participants, and do not necessarily represent the views of the WEDI Board of 
  Directors nor WEDI SNIP. If you wish to receive an official opinion, post your 
  question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. 
  These listservs should not be used for commercial marketing purposes or 
  discussion of specific vendor products and services. They also are not 
  intended to be used as a forum for personal disagreements or unprofessional 
  communication at any time.You are currently subscribed to wedi-privacy 
  as: [EMAIL PROTECTED]To unsubscribe from 
  this list, go to the Subscribe/Unsubscribe form at http://subscrib