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RISK MANAGEMENT PROCESS For Healthcare
Organizations
1
2
Operating Snapshot
Starting this year, providers
can be fined up to $1.5
million for a HIPAA violation
• Security is Not Optional
Number of volunteers and
3rd party personals
supporting hospitals is just
too large that it is generally
impossible to manually
control access
• Large Number of Temporary Workers
Clinicians are often
overworked and intuitively
bring tools to help improve
productivity
• Consumer Devices need to be Secured
Hospitals tend to rely on
multitudes of applications,
often hosted and managed
by 3rd party vendors
• Need to Adapt and Federate
Patient care is of utmost
importance and hence the
access to patient data must
be available in case of
emergencies
• Break Glass Functionality
Clinicians on the floor
typically share computers
and (most often password)
• Quick switching
We Know the Healthcare Environment
3
Common Risks
Data and Information Explosion
 Data volumes are doubling every 18 months.
 Storage, security, and discovery around information
context is becoming increasingly important.
Care Continuum
 The chain is only as strong as the weakest link.
Partners need to shoulder their fair share of the
load for compliance and the responsibility for
failure.
Patients Expect Privacy
 An assumption or expectation now exists to
integrate security into the infrastructure, processes
and applications to maintain privacy.
Compliance fatigue
 Organizations are trying to maintain a balance
between investing in both the security and
compliance postures.
Emerging Technology
 Virtualization and cloud computing increase
infrastructure complexity.
 Web 2.0 and SOA style composite applications introduce
new challenges with the applications being a vulnerable
point for breaches and attack.
Wireless World
 Mobile platforms are developing as new means of
identification.
 Security technology is many years behind the security
used to protect PCs.
Risk ManagementPeople
• Drug Testing
• Background Testing
• NDAs
• HIPAA Compliance
Training
Process
• Identify what needs to
be audited and
controlled
• Define Who needs
Access to What
• Establish auditing and
control processes
Tools
• Restricted physical
access
• Restricted equipment
access
• Restricted network
access
• Restricted data access
• Email & Web
Monitoring
People- Onboarding Checklist
 Calance employees sign Non-Disclose Agreements
with specific to the client.
 Every employee signs a “ Work for Hire” contract
for the client transferring the intellectual property
to the client.
 Background checks and drug testing
 All Calance employees, in Healthcare COE,
have to go through background checks and 10
panel drug testing.
 Calance HR maintains a chain of custody for
all records
 Customers are provided a copy of the reports,
if needed
Onboarding Process
People-Training
Compliance Training
 Calance uses an in-house LMS for training
and skills assessment
 Every employee is required to complete
mandatory HIPAA Compliance and Privacy
training*
 At the end of the training, the employees
are prompted for test scenarios
 HIPAA compliance training can be
scheduled periodically, based on client
needs * Training material sourced from certified trainers or based
on client requirements
http://www.hhs.gov/ocr/privacy/hipaa/understanding/trai
ning/
Training
Tools- Restricted Office Space
Calance can create physical separation of staff in Gurgoan (India) and Buena
Park, CA offices
 Restricted office space uses bio-metric scanners and RFID cards
 Access to the restricted floor requires a PIN, changed periodically
 Single on-boarding and off-boarding process, shared with the client
 Data Center access requires additional approvals from System Engineering
and a VP
Tools- Network and Equipment
Network and Equipment Access
 Healthcare clients are cordoned in their own subnet
 Point -to-point encryption between client network and
Calance
 Encrypted Hard Disks and/or Bitlocker
 All computers utilize client specific software images
 No admin access to install personal software
 No access to USB ports
 No backup devices are allowed on the restricted floor
 Use two factor authentication for access the network
Equipment
& Access Control
TECHNOLOGY AND AUDITING
9
Process Overview
Administration & Auditing
Administration and Auditing
 Calance has a 24x7 NOC in Buena Park, CA,
monitoring infrastructure hosted in our data
center, client locations, co-location facilities
and public cloud
 Systems Engineering works with the
compliance and security architects to create
Role Based Access
 Besides typical monitoring, Calance NOC can
audit emails and web traffic for any policy
violations
Federated Cloud Security Solutions
 Calance employees are certified in
architecting and setting-up enterprise
systems on Amazon EC2 and Microsoft
Azure*
*See HIPAA Compliant Hybrid Cloud Service Offering
Technology Partnerships
 We have established strategic
partnerships with the industry
leaders for Identify & Access
Management solutions in the
Healthcare industry
 Calance has deployed custom
solutions at reputed Healthcare
organizations using these tools
Process- Audit and Process Improvements
 Calance employs an independent agency for yearly
audit of security procedures
 Current Certifications
Continuous
Improvement
CMM Level 5 and ISO 9001: 2008 Certified
for quality and project management
processes.
SSAE 16 Type II certified datacenter, help
desk, application & desktop support.
CONTACT US
Calance Healthcare Practice
2018, 156th Ave NE
Suite 100
Bellevue, WA 98007
Gaurav Garg
Vice President
ggarg@calance.com
Tel: 425-605-0716
Cell: 818-620-0329
13
www.calance.com
info@calance.com
866-736-5500 (Toll-Free)

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Building HIPAA Compliance in service delivery teams

  • 1. RISK MANAGEMENT PROCESS For Healthcare Organizations 1
  • 2. 2 Operating Snapshot Starting this year, providers can be fined up to $1.5 million for a HIPAA violation • Security is Not Optional Number of volunteers and 3rd party personals supporting hospitals is just too large that it is generally impossible to manually control access • Large Number of Temporary Workers Clinicians are often overworked and intuitively bring tools to help improve productivity • Consumer Devices need to be Secured Hospitals tend to rely on multitudes of applications, often hosted and managed by 3rd party vendors • Need to Adapt and Federate Patient care is of utmost importance and hence the access to patient data must be available in case of emergencies • Break Glass Functionality Clinicians on the floor typically share computers and (most often password) • Quick switching We Know the Healthcare Environment
  • 3. 3 Common Risks Data and Information Explosion  Data volumes are doubling every 18 months.  Storage, security, and discovery around information context is becoming increasingly important. Care Continuum  The chain is only as strong as the weakest link. Partners need to shoulder their fair share of the load for compliance and the responsibility for failure. Patients Expect Privacy  An assumption or expectation now exists to integrate security into the infrastructure, processes and applications to maintain privacy. Compliance fatigue  Organizations are trying to maintain a balance between investing in both the security and compliance postures. Emerging Technology  Virtualization and cloud computing increase infrastructure complexity.  Web 2.0 and SOA style composite applications introduce new challenges with the applications being a vulnerable point for breaches and attack. Wireless World  Mobile platforms are developing as new means of identification.  Security technology is many years behind the security used to protect PCs.
  • 4. Risk ManagementPeople • Drug Testing • Background Testing • NDAs • HIPAA Compliance Training Process • Identify what needs to be audited and controlled • Define Who needs Access to What • Establish auditing and control processes Tools • Restricted physical access • Restricted equipment access • Restricted network access • Restricted data access • Email & Web Monitoring
  • 5. People- Onboarding Checklist  Calance employees sign Non-Disclose Agreements with specific to the client.  Every employee signs a “ Work for Hire” contract for the client transferring the intellectual property to the client.  Background checks and drug testing  All Calance employees, in Healthcare COE, have to go through background checks and 10 panel drug testing.  Calance HR maintains a chain of custody for all records  Customers are provided a copy of the reports, if needed Onboarding Process
  • 6. People-Training Compliance Training  Calance uses an in-house LMS for training and skills assessment  Every employee is required to complete mandatory HIPAA Compliance and Privacy training*  At the end of the training, the employees are prompted for test scenarios  HIPAA compliance training can be scheduled periodically, based on client needs * Training material sourced from certified trainers or based on client requirements http://www.hhs.gov/ocr/privacy/hipaa/understanding/trai ning/ Training
  • 7. Tools- Restricted Office Space Calance can create physical separation of staff in Gurgoan (India) and Buena Park, CA offices  Restricted office space uses bio-metric scanners and RFID cards  Access to the restricted floor requires a PIN, changed periodically  Single on-boarding and off-boarding process, shared with the client  Data Center access requires additional approvals from System Engineering and a VP
  • 8. Tools- Network and Equipment Network and Equipment Access  Healthcare clients are cordoned in their own subnet  Point -to-point encryption between client network and Calance  Encrypted Hard Disks and/or Bitlocker  All computers utilize client specific software images  No admin access to install personal software  No access to USB ports  No backup devices are allowed on the restricted floor  Use two factor authentication for access the network Equipment & Access Control
  • 10. Administration & Auditing Administration and Auditing  Calance has a 24x7 NOC in Buena Park, CA, monitoring infrastructure hosted in our data center, client locations, co-location facilities and public cloud  Systems Engineering works with the compliance and security architects to create Role Based Access  Besides typical monitoring, Calance NOC can audit emails and web traffic for any policy violations Federated Cloud Security Solutions  Calance employees are certified in architecting and setting-up enterprise systems on Amazon EC2 and Microsoft Azure* *See HIPAA Compliant Hybrid Cloud Service Offering
  • 11. Technology Partnerships  We have established strategic partnerships with the industry leaders for Identify & Access Management solutions in the Healthcare industry  Calance has deployed custom solutions at reputed Healthcare organizations using these tools
  • 12. Process- Audit and Process Improvements  Calance employs an independent agency for yearly audit of security procedures  Current Certifications Continuous Improvement CMM Level 5 and ISO 9001: 2008 Certified for quality and project management processes. SSAE 16 Type II certified datacenter, help desk, application & desktop support.
  • 13. CONTACT US Calance Healthcare Practice 2018, 156th Ave NE Suite 100 Bellevue, WA 98007 Gaurav Garg Vice President ggarg@calance.com Tel: 425-605-0716 Cell: 818-620-0329 13 www.calance.com info@calance.com 866-736-5500 (Toll-Free)