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Appropriate Monitoring for Electronic Patient Records
The Department of Health and Human Services this week released new privacy guidelines (PDF) for electronic health records, the use of which President-elect Barack Obama has promised to support as part of his plan to jump-start the economy.
Some quotes from this report:
SAFEGUARDS Individually identifiable health information should be protected with reasonable administrative, technical, and physical safeguards to ensure its confidentiality, integrity, and availability and to prevent unauthorized or inappropriate access, use, or disclosure.
ACCOUNTABILITY These principles should be implemented, and adherence assured, through appropriate monitoring and other means and methods should be in place to report and mitigate non-adherence and breaches.
Unfortunately the principles are still high-level and offer no specific guidance on how to safeguard health information beyond recommending "appropriate monitoring". We have often recommended the Payment Card Industry's data security standard of a great example for a standard which is both crisp and concrete offering specific guidance. A couple of tips for the new administration:
1. How NOT to protect health information:
According to breach blog, just last week (12/12/2008) 890 patients from the Oregon Health & Science University in Chicago lost "medical record numbers, names, telephone numbers, dates of birth, gender, medical diagnosis category and category of treatment" due to a stolen laptop.
2. How to do right by your patients
Visiting Nurse Service of New York protects patient records for 131,000 patients through "appropriate monitoring". The organization tracks all IT activity, including access to health information, by collecting log data from approximately 4,000 mobile nurses with tablet PCs, 8,000 technology accounts, 324 servers and an additional end-points. “As I see it, logging is really the beginning of all computer intelligence,” says Larry Whiteside, Jr., Chief Information Security Officer for VNSNY.
Larry is my super-hero of the month and I encourage policy makers in health IT to look him up.
Posted December 18, 2008 in | Permalink
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