If I get a sit-down with the HIPAA compliance officer for the hospital
here I am going to need to get someone else on the phone with them who
is knowledgeable about HIPAA compliance who can help me sell the idea
that wireless can be used in HIPAA compliant data transmission systems.
Would yo be that person? If so then send me the best number to reach you
at. I will let you know when I will have this meeting to make sure it is
a time when you could talk if needed.
Thanks,
Scriv
Peter R. wrote:
A HIPAA consultant was at my luncheon yesterday. He pulled all this
info for you:
pulled a couple things below as background as well as the actual
regulation. The one that pertains to this discussion is the last
paragraph below. There is no strict rule as to how to secure and in
actual fact, switched or dial-up networks are deemed more secure due
to the random nature of the connection.
http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=2003_register&docid=fr20fe03-4.pdf
The HIPAA Security Rule establishes specific requirements for securing
all electronic protected health information (EPHI) -- while at rest
(in servers or storage) or in motion (in transmission, wireless or
wired).
‘‘Transmission security (refers to)… electronic protected health
information is transmitted from one point to another, it must be
protected in a manner commensurate with the associated risk.”
§ 164.312 Technical safeguards.
A covered entity must, in accordance with § 164.306:
(a)(1) Standard: Access control. Implement technical policies and
procedures for electronic information systems that maintain electronic
protected health information to allow access only to those persons or
software programs that have been granted access rights as specified in
§ 164.308(a)(4).
(2) Implementation specifications: (i) Unique user identification
(Required). Assign a unique name and/or number for identifying and
tracking user identity. (ii) Emergency access procedure (Required).
Establish (and implement as needed) procedures for obtaining necessary
electronic protected health information during an emergency. (iii)
Automatic logoff (Addressable). Implement electronic procedures that
terminate an electronic session after a predetermined time of
inactivity. (iv) Encryption and decryption (Addressable). Implement a
mechanism to encrypt and decrypt electronic protected health information.
(b) Standard: Audit controls. Implement hardware, software, and/or
procedural mechanisms that record and examine activity in information
systems that contain or use electronic protected health information.
(c)(1) Standard: Integrity. Implement policies and procedures to
protect electronic protected health information from improper
alteration or destruction. (2) Implementation specification: Mechanism
to authenticate electronic protected health information (Addressable).
Implement electronic mechanisms to corroborate that electronic
protected health information has not been altered or destroyed in an
unauthorized manner.
(d) Standard: Person or entity authentication. Implement procedures to
verify that a person or entity seeking access to electronic protected
health information is the one claimed.
(e)(1) Standard: Transmission security. Implement technical security
measures to guard against unauthorized access to electronic protected
health information that is being transmitted over an electronic
communications network. (2) Implementation specifications: (i)
Integrity controls (Addressable). Implement security measures to
ensure that electronically transmitted electronic protected health
information is not improperly modified without detection until
disposed of. (ii) Encryption (Addressable). Implement a mechanism to
encrypt electronic protected health information whenever deemed
appropriate.
Daniel L. Ruggles
CISSP, CISM, CMC, IAM, PMP
Principal
Liaison Technologies, LLC
--
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