HIPAA Compliance – Access Controls, Authentication, and EHR Data Integrity
In light of the recent massive security breaches at UCLA Medical Center and Anthem Blue Cross, keeping your EHR secure has become all the more important. However, as organizations work to prevent data breaches, it can be difficult to find a balance between improving security and maintaining accessibility. To that end, HIPAA Chat host Steve Spearman addresses digital access controls, common authentication problems, and how authentication meets HIPAA compliance and helps ensure the integrity of your EHR, even after multiple revisions.
Q: What are access controls?
A: Access controls are mechanisms that appropriately limit access to resources. This includes both physical controls in a building, such as security guards, and digital controls in information systems, such as firewalls. Having and maintaining access controls are a critical and required aspect of HIPAA compliance, and is the first technical HIPAA Security Standard.
Q: What’s the most common form of digital access control we see in healthcare?
A: The username and password is the most common form of access control by far. The Access Control Standard requires covered entities to give each user a distinct and unique user ID and password in order to access protected information. These unique credentials for each employee enable covered entities to confirm (“authenticate”) the identity of users and to track and audit information access.
Q: What are the most common problems with access controls and use of passwords in healthcare?
A: The most common problem is that covered entities often use multiple systems which each may require its own set of usernames and passwords along with varying requirements for these credentials, such as minimum character length or use of capital letters. Memorizing multiple sets of passwords and usernames for multiple systems is difficult for most people. In addition, there is a conundrum between password complexity and memorization. Complex passwords (longer with multiple required character types) are better for security but much harder to memorize. This is the conundrum.
Q: Are stricter password policies always more secure?
A: No, if passwords requirement are too strict, users then use coping mechanisms such as writing them down or re-using the same password over and over and across multiple systems. This compromises security rather than enhancing it. For example, a policy that required 14 digit passwords and required, lower-case, upper-case, numbers and symbols and expired every 30 days would create huge problems for most organizations. With these policies, staff would simply write down their passwords. But this compromises security. If a bad person gets a hold of a written list of passwords they have the “keys to the kingdom”, the ability to access the accounts on that written list. So passwords should not be written down.
In addition, overly strict password policies tend to overwhelm technical support staff with password reset requests.
So passwords should be sufficiently complex to make them hard to crack which also makes them hard to memorize.
Q: This sounds like a big problem. Do you have any suggestions to make things better?
A: At a minimum, organizations need to provide training to staff on straightforward techniques to create memorable but complex passwords. I have an exquisitely terrible memory. But I have great passwords using one particular technique. Just google “create good memorable passwords” and you can find dozens of videos demonstrating how to do it. But, of course, our favorite is the video featuring our very own, Gypsy, the InfoSec Wonderdog, which you can find here.
Enterprises should seriously consider additional technical solutions such as two factor authentication with single sign on (2FA/SSO).
Q: What is a good, reasonable password policy?
A: I recommend a policy that:
- Requires a minimum of 8 characters
- Requires two or three of the options of lower-case, upper-case, numbers and symbols
- Expire every 3 to 6 months
- And limit limit use of historical passwords so that the previous two cannot be used.
Q: You mentioned authentication before. What is that? What is two-factor or multi-factor authentication?
A: Authentication is the process of confirming the identity of a person before granting access to a resource. Computer geeks refer to the three factors of authentication:
- What a user has (an ID badge or phone).
- What a user knows (a PIN number)
- Who a user is (biometrics)
For example, ATMs use two-factor authentication:
- What the user has: an ATM card and
- What they know: a PIN.
One of my favorite tools for two factor authentication is Google Authenticator which runs as an app on my mobile phone. Another common form of two factor authentication is text codes. With this method, the website or app, after entering a correct username and password, sends a text with a numeric code that expires after a few minutes to your phone that is entered into another field in the website before access is granted.
Everyone should enable two factor authentication on their most essential systems such as to online banking and to email accounts such as gmail.
In healthcare, there is a growing trend toward biometric authentication, the use of fingerprint readers or palm readers, etc. to authenticate into systems. Biometric authentication is generally very secure and is also very easy to use since there is nothing to memorize.
Q: What is SSO?
A: Single sign-on (SSO) lets users access multiple applications through one authentication event. In other words, one password allows access to multiple systems. It enhances security because users only have to remember one password. And because it is just one, it is commonly a good complex password. Once entered, it will allow access to all the core systems (if enabled) without having to re-authenticate.
Single sign-on combined with two factor authentication or biometrics work great together in tandem and are often sold together by vendors. The leading SSO/2FA vendor in healthcare is Imprivata, but there are other vendors making great in-roads into healthcare such as Duo Security, 2FA.com and Secureauth.com.
Q: What do you mean by “integrity” and what does it have to do with access control and authentication?
A: Integrity in System Standards is the practices used to track and verify all changes made to a health record. It is a condition that allows us to prevent editing or deleting of records without proper authorization.
Authentication and access controls are the primary means we use to preserve integrity of a record. If the information system is programmed to track its users’ activity, then it’s possible to track who made changes to a record and how they changed it.
This is why users should never share usernames and passwords with other users. Integrity becomes impossible if a username does not signify the same user every time it appears.
Q: Any final thoughts?
A: Finding that balance between HIPAA compliance, security and accessibility can be tricky. We recommend reducing digital access controls to a single multi-factor authentication or biometrics event. This single, secure method of authentication could be the balance between security and efficiency needed to keep your EHR secure and yet accessible. In addition to improving accessibility to your system, an MFA or biometrics sign-in method could help improve your organization’s EHR integrity. If you have questions about physical or digital access controls, contact Health Security Solutions here.
Steve Spearman hosts HIPAA Chat, a show produced by HITECH Answers airing on our Internet radio station, HealthcareNOWradio.com. Learn more about HIPAA Chat or download podcasts of the show. Find out more about attending the next taping of HIPAA Chat and ask your questions directly to Steve.