9:00 a.m.–10:00 a.m. |
Tuesday |
Speaker: Adam H. Greene, Davis Wright Tremaine LLP
The federal and state governments have investigated thousands of health care privacy and security cases, received tens of thousands of healthcare breach reports, audited dozens of health care entities, and entered into a few high-profile financial settlements. These enforcement efforts offer a wealth of knowledge on the threats facing the health care industry, the privacy and security issues that represent the largest legal risks, and how improvements can be made. This presentation will analyze past enforcement trends and offer analysis and lessons about ways health care providers and plans can improve the privacy and security of some of our most sensitive information. The federal and state governments have investigated thousands of health care privacy and security cases, received tens of thousands of healthcare breach reports, audited dozens of health care entities, and entered into a few high-profile financial settlements. These enforcement efforts offer a wealth of knowledge on the threats facing the health care industry, the privacy and security issues that represent the largest legal risks, and how improvements can be made. This presentation will analyze past enforcement trends and offer analysis and lessons about ways health care providers and plans can improve the privacy and security of some of our most sensitive information.
Adam Greene is a partner in the Washington, D.C., office of Davis Wright Tremaine, where he primarily counsels health care providers and technology companies on compliance with the HIPAA privacy, security, and breach notification rules. Previously, Adam was a regulator at the U.S. Department of Health and Human Services, where he played a fundamental role in administering and enforcing the HIPAA rules. At HHS, Adam was responsible for determining how HIPAA rules apply to new and emerging health information technologies, and he was instrumental in the development of the current HIPAA enforcement process. Adam is the Chair of the HIMSS Cloud Security Workgroup and a member of the AHIMA Emerging Issues Practice Council.
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10:00 a.m.–10:30 a.m. |
Tuesday |
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10:30 a.m.–Noon |
Tuesday |
Tobias Dehling and Ali Sunyaev, University of Cologne, Germany
Health information technology can have positive impacts on healthcare delivery and is utilised for various applications. Patient-centred services are a special kind of health information technology and are designed to cater to patients' needs. They manage personal medical information and utilise such information to offer personalised, advantageous services as well as information for patients. Due to the sensitivity of medical information and the gravity of possible consequences, if medical information falls into the wrong hands, patient-centred services need to employ security measures to ensure the privacy of patients. The German Nationwide Health Information Technology Infrastructure (HTI), which is currently being established, could serve as a fit and proper foundation for securely offering patient-centred services. In this paper, we illustrate the past developments and current status of the HTI introduction with a focus on security aspects related to patient-centred services. We depict how security features of the HTI can be applied to improve secure provision of patient-centred services. Furthermore, we present additional security measures that should be implemented by providers of patient-centred services.
Patrick Morrison and Laurie Williams, North Carolina State University
As software developers, we have a responsibility to protect our user’s data. When this data is protected health information (PHI), breaches can have serious financial and reputational consequences. The goal of this research is to analyze trends in breaches of PHI that point to software design guidelines that can prevent or lessen the impact of breaches. We examine the US Office of Civil Rights public data on HIPAA breach notifications and examine some of its implications for software system design We observe that a significant number of breaches involve the use of portable stores of unencrypted records and present software design strategies to address these breaches before they happen.
Nathanael Paul, University of Tennessee, Oak Ridge National Laboratory; Tadayoshi Kohno, University of Washington
Portable implantable medical device systems are playing a larger role in modern health care. Increasing attention is now being given to the wireless control interface of these systems. Our position is that wireless security in portable implantable medical device systems is just a part of the overall system security, and increased attention is needed to address low-tech security issues.
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Noon–1:30 p.m. |
Tuesday |
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1:30 p.m.–3:15 p.m. |
Tuesday |
Xuan Hung Le and Dongwen Wang, University of Rochester Medical Center
We previously developed an enhanced Role-Based Access Control (RBAC) model to support information access management in the context of team collaboration and workflow. We report in this paper a generic system framework to implement the enhanced RBAC with three functional layers: (1) encoding of access control policies; (2) interpretation of the encoded policies; and (3) application of policies to specific cases and scenarios for information access management. Based on this system framework, we have successfully applied the enhanced RBAC model to the New York State HIV Clinical Education Initiative (CEI) for coordination of clinical education programs. An evaluation has shown that the enhanced RBAC can be effectively used for information access management in collaborative processes. Future work includes extension of this system framework to support the continuous development of the enhanced RBAC and deployment of it to other domain applications for clinical education, biomedical research, and patient care.
Quanyan Zhu, Carl Gunter, and Tamer Başar, University of Illinois at Urbana-Champaign
The challenge of moving a decentralized, fragmented, paper-based healthcare system to an interconnected, automated, networked world is not merely technological. Digital right management (DRM) technologies can be leveraged as a tool to protect the privacy of electronic health records (EHRs) via encryption, access control, etc. However, the deployment of DRM technology needs to address special requirements for the healthcare system. One of the critical issues is that there is no clearly defined data ownership, and multiple parties own different pieces of a patient’s medical history. The fractured ownership of medical information among medical service providers and insurers has created the tragedy of anticommons for implementation of DRMs. In this work, we investigate DRM under multiple ownerships of medical data, and employ game-theoretic tools to study and understand the strategic behaviors of different owners in the healthcare system. Our approach aims to address the underutilization of EHR resources, and provides a theoretical basis for mechanism design of economic policies to improve social welfare and efficiency of the electronic healthcare system.
Omar Chowdhury, The University of Texas at San Antonio; Haining Chen, Purdue University; Jianwei Niu, The University of Texas at San Antonio; Ninghui Li and Elisa Bertino, Purdue University
In the medical sphere, personal and medical information is collected, stored, and transmitted for various purposes, such as, continuity of care, rapid formulation of diagnoses, and billing. Many of these operations must comply with federal regulations like the Health Insurance Portability and Accountability Act (HIPAA). To this end, we need a specification language that can precisely capture the requirements of HIPAA. We also need an enforcement engine that can enforce the privacy policies specified in the language. In the current work, we evaluate eXtensible Access Control Markup Language (XACML) as a candidate specification language for HIPAA privacy rules. We evaluate XACML based on the set of features required to sufficiently express HIPAA, proposed by a prior work. We also discuss which of the features necessary for expressing HIPAA are missing in XACML. We then present high level designs of how to enhance XACML’s enforcement engine to support the missing features.
Yifei Wang, Sean Smith, and Andrew Gettinger, Dartmouth College
In theory, access control is a solved problem. In practice, large real-world enterprises still report trouble: de facto policy becomes unmanageable; users circumvent controls. These issues can be particularly critical in medical IT, such as emerging EMR and EHR, where access control errors can have serious repercussions. In this paper, we investigate how real-world EMR users think about access control when they are making policy decisions in the abstract–and when they are actually using the system in treatment scenarios. Mismatches suggest places (“empathy gaps”) where new policy tools may be needed.
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3:15 p.m.–3:45 p.m. |
Tuesday |
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3:45 p.m.–4:45 p.m. |
Tuesday |
Jason King and Laurie Williams, North Carolina State University
Both health information technology (HIT) and the payment card industry (PCI) involve the exchange and management of sensitive, protected information. Compared to the PCI, HIT could consider protected health information (PHI) more sensitive than PCI cardholder data. If cardholder data is breached in the PCI, payment card companies may then remove fraudulent charges from the customer’s account and/or issue the customer a new payment card. However, once a person’s PHI has been breached, the PHI has been breached forever. Healthcare organizations cannot issue new health histories or new identities to affected individuals. Secure logging and auditing may deter users from performing unauthorized transactions with PHI since an irrefutable trace of the user’s activity is recorded. Logging and auditing also provides an accounting of PHI disclosures for assisting data breach investigations.
Secure logging and auditing is one mechanism EHR systems should implement to promote security, user accountability, and trust. The objective of this paper is to raise awareness of issues around electronic health record logging and auditing mechanisms through a comparison with the Payment Card Industry Data Security Standards. With the recent push to move all health records to electronic format, the healthcare industry needs to define better standards for secure logging and auditing in EHR systems.
Daisuke Mashima and Mustaque Ahamad, Georgia Institute of Technology
In the United States, the transition from traditional paper-based healthcare records to electronic healthcare record (EHR) systems is being promoted aggressively. While EHR systems offer a number of benefits, they will introduce new security and privacy concerns. A significant fraction of such threats, at least in part, arise due to actions of insiders of healthcare organizations, either accidentally or intentionally. We believe information accountability, which allows us to securely identify how a health record reached a certain consumer and who was involved in its sharing or transfer, is a key to discourage such threats. In this work, we propose a patient-centric scheme to establish robust information accountability in electronic healthcare record sharing systems. We also present a prototype implementation and show that it does not impose unacceptable performance overhead.
Joseph Lorenzo Hall, New York University; Benedicte Callan, University of Texas at Austin; Helen Nissenbaum, New York University
We propose an orthogonal artifact to the HIPAA Privacy Rule's Accounting of Disclosure (AOD). Instead of the patient-centric AOD, we propose a provider-centric "Accounting of Relationships" that aggregates "data flows" involving PHI across all patients. This AOR artifact allows a number of complementary uses in conjunction with the AOD, but also allows meaningful comparisons of PHI data flows across provider institutions.
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4:45 p.m.–5:00 p.m. |
Tuesday |
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