While organizations should focus on performing regular risk assessments and analyses, there are also other ways in which they must review their systems for compliance. Often, these other evaluations are overlooked despite their value, says Kevin Beaver, CISSP, an information security consultant in Atlanta. In particular, organizations should be careful not to forget about performing vulnerability assessments and penetration tests, which are components of an overall risk assessment or analysis, says Beaver, who is a BOH editorial advisory board member.
In my experience, most organizations in the health-care industry?both covered entities and business associates?have taken the steps to put policies, business processes, and training programs in place to help ensure compliance with the HIPAA Security Rule. Still, there's a gaping hole in many healthcare compliance and security programs: a lack of technical security testing of Web applications, mobile applications, and network systems.
As the use of electronic health records (EHR) surges and organizations work toward meaningful use attestation, more in-depth monitoring of electronic patient records is becoming increasingly necessary.
Q: I am familiar with the HIPAA Security Rule requiring information system review audits. Are there any HIPAA Privacy Rule requirements?other than to perform audits?that require the examination of inappropriate access for an alleged breach? Currently, our security team performs monthly information system review audits and issues reports to leadership on a quarterly basis. Will this suffice, or are there audits that the privacy team should perform as well?
