Panaceas, Shiny Objects and the Importance of Managing Risk in a Healthcare Environment – Part 2

Healthcare CIOs, CISOs, and other information risk management leaders face daunting challenges when it comes to deciding where to apply their limited resources to make the biggest difference in their organization’s cyber risk posture. As I mentioned in my previous post, healthcare security leaders can be tempted by shiny new objects – i.e., new security tools – that promise to be the panacea to their most pressing security problems.

Cyber security leaders can also be distracted by Executive Board members and other stakeholders who prioritize the cyber threat of the day. They may respond to cyber attack headlines by button-holing the CISO and asking, “What are we doing about THIS???”


The solution to a scattershot, reactive approach to cyber security is to develop an enterprise cyber risk management system (ECRMS). And the first step in developing an ECRMS, is conducting a HIPAA-compliant risk assessment and analysis.

HIPAA Compliance and Risk Assessment

HIPAA’s Security, Privacy and Breach Notification Rules are designed to ensure the confidentiality, integrity and availability (CIA) of protected health information (PHI). HIPAA’s Security and Privacy Rules apply to any entity that “creates, receives, maintains or transmits protected health information” per 45 C.F.R. § 160.103. This means that whether you are a healthcare provider, a health plan, a healthcare clearinghouse or a business associate of any of this entities, HIPAA applies to you.

The HIPAA Security Rule actually defines three different types of assessments that organizations must conduct in order to be compliant. Those three types of assessments include:

• HIPAA Security Non-Technical Evaluation, a.k.a. Compliance Gap Assessment
• HIPAA Security Technical Evaluation, a.k.a. Technical Testing
• HIPAA Security Risk Assessment/Analysis

The difference between these three types of assessments is a topic for another blog post. What’s important to understand for our purposes is that organizations must conduct all three types of security assessments in order to be HIPAA compliant. One type of assessment (for example, Technical Testing or Compliance Gap Assessment) cannot be substituted for another type of assessment (Risk Assessment/Risk Analysis).

The first step – the foundational step – in developing an enterprise cyber risk management system, is to conduct a security risk assessment and analysis as defined within the HIPAA Security Rule. Two other information sources help to provide a comprehensive and detailed definition of what a HIPAA-compliant risk assessment looks like: first, OCR guidance – including the results of OCR enforcement actions and audits – gives a clear picture of what a comprehensive risk analysis includes. Second, NIST standards around information security provide a model for how to properly conduct a risk assessment – and how to start developing a strategic framework once you have the assessment results.

What an OCR-Quality Risk Analysis Entails

At its most basic level, risk analysis includes three primary tasks:

1. Identifying risk
2. Rating risk
3. Prioritizing risk

Identifying risk starts with identifying and documenting every information asset in your organization. Information assets include all electronic equipment, data systems, programs and applications that are controlled, administered, owned or shared by an organization and which contain, transmit or store ePHI. This includes traditional forms of assets, such as IT systems and applications (e.g., EHR systems, clinical information applications, lab applications, medical billing and claims processing applications, email applications, etc.).

Information assets also include biomedical assets, such as patient monitoring devices, implantable devices, and remote chronic disease management applications. Internet of Things (IoT) assets must also be included in your asset inventory. (Incidentally, a key challenge for hospitals and health systems in conducting a comprehensive information asset inventory has been their capability to identify and document electronic medical devices. New technology from IoMT / HIoT security companies identifies medical devices, device types, software versions and VLAN location via passive observation of biomedical network traffic without threatening a device.)

Risk analysis does not stop with a simple inventory of information assets, however. Risk has three components: an asset, a threat, and a vulnerability. Adequately identifying risk means addressing each of these components for each information asset. For example, an information asset might be a tablet computer used by staff or clinicians. One threat to that tablet could be theft. Vulnerabilities that create risk when that table is stolen include a lack of encryption, weak passwords, and a lack of data backup. In other words, each information asset can be compromised by many different types of threats. In turn, those threats become real due to the vulnerabilities associated with them.

A comprehensive, HIPAA-compliant risk assessment requires documentation of a considerable amount of detail. It’s easy to see how healthcare organizations who attempt to conduct an inventory of information assets, with their associated threats and vulnerabilities, are quickly overwhelmed with pages and pages of spreadsheets.

Rating and Prioritizing Risk

And yet there is more.

Because a bona fide, OCR-compliant risk analysis includes not only identifying information assets, threats and vulnerabilities, but also rating risk. This involves estimating the likelihood (probability) and impact (degree of harm or loss) on the organization of each possible asset/threat/vulnerability combination. Which makes our spreadsheet even more complex. 

After all information assets have been inventoried, all asset/threat/vulnerability combinations have been documented, and the likelihood and impact of each potential risk calculated, the result is a “risk rating” for each potential threat.

The beauty of the risk rating is that it allows each healthcare organization to identify, rate and prioritize the particular risks associated with that organization’s unique information asset inventory, threat/vulnerability combinations, and calculated risks.

Each organization is able to establish their own risk threshold. For example, an organization might specify a risk rating of “20” as their threshold. That means that information risk management strategic priorities would center on mitigating risks for those items that rated 20 or higher. In the example above, security leadership would be able to use this information to make a persuasive case for security tools that enabled encryption of ePHI contained on tablet computers, as the “25” risk rating indicates this risk is a high priority for this organization.

The Value of a Comprehensive Risk Analysis

Conducting an OCR-quality, security risk assessment and analysis has value for healthcare organizations beyond assuring compliance with HIPAA guidelines. As the example above illustrates, a comprehensive risk analysis helps security leaders not only identify, but also rate and prioritize enterprise-wide cyber security threats.

The information uncovered by the risk analysis can help security leaders develop relevant and meaningful cyber risk management systems by providing a framework for making decisions. With an accurate and updated security risk assessment in place, security leaders no longer have to make purchasing decisions based on the strength of a vendor’s demo, or in reaction to cyber threat headlines. With a security risk assessment and analysis in place, healthcare security leaders are empowered to make proactive and strategic decisions about the tools and strategies that will mitigate their highest priority risks.

In the third part of this 3-part series, Panaceas, Shiny Objects and the Importance of Managing Risk in a Healthcare Environment, I will explore some of the resources, solutions and services that can not only help security leaders efficiently conduct a security risk analysis, but also help healthcare security leaders leverage the completed security risk analysis to develop an enterprise cyber risk management system.
 

Check out the first blog in this series here: Panaceas, Shiny Objects and the Importance of Managing Risk in a Healthcare Environment–Part 1

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HIoT and Third Party Vendor Risk

The rising number of non-IT devices plugged in, or connected wirelessly, to hospital networks far overshadows the number of PCs, laptops and workstations in most facilities. What is more, most of these IoT devices have no security protections and cannot easily be patched. Medical devices are growing at 20% per annum and are often owned and managed outside of hospital IT and Security teams. No wonder then, that hospital CEOs are becoming concerned at the patient safety ramifications of one of these devices being compromised by a malicious hacker.

Widespread automation and cost cutting across hospitals is leading to a rising trend of the outsourcing of hospital building management systems (BMS). This includes everything from electrical and water distribution to elevators and HVAC. Most of these outsource agreements are with companies from many miles away – often out of State, or out of Country, who manage systems remotely via a virtual private network (VPN). Usually governed by weak or incomplete third-party contracts which are rarely audited, these agreements extend the hospital attack surface into the outsource company complete with all of their security vulnerabilities. Scholars of prior cybersecurity attacks will be quick to point out the parallels here between Target Stores and its HVAC services provider Fazio Mechanical, which resulted in one of the largest cyber-thefts of credit card numbers as well as most of Target’s customer information. The breach cost Target millions in compensation, restitution and credit monitoring, as well as the jobs of everyone in leadership and two class action lawsuits.

The repercussions of third-party vendor breach in healthcare could however, be far more nefarious and impactful given what is connected to the typical hospital network. That is, unless networks are properly and securely segmented to isolate hospital building management systems, operational technology, medical devices, and business IT systems. However very few hospitals have so far even started to securely segment their large flat networks in order to isolate the really risky endpoints.

The need to evaluate third party risk is critical

The need therefore to evaluate third party risk is critical, yet most hospitals currently don’t do this well if at all. With thousands of suppliers, vendors, contractors and consultants in each hospital, manual assessment is simply too much to handle with the current number of security and compliance staff.

As healthcare leaders continue to monitor and evaluate what is meant by patient safety in their operations, it’s clear that today, patient safety means so much more than just avoiding medical errors or someone slipping on a freshly mopped hospital floor.

The author addresses these and other subjects at the South Dakota HIMSS annual Conference today 
in Sioux Falls, SD.

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Panaceas, Shiny Objects and the Importance of Managing Risk in a Healthcare Environment – Part 1

You’re the CISO of a healthcare organization and you just sat through an amazing sales presentation by one of your security vendors. You are considering cutting a PO to purchase that new security tool. You’ve been thinking for some time about purchasing tools to close security gaps that you’re aware of and this particular tool appears to address a critical area of weakness in your information security program.

At the same time, you’ve got limited resources for addressing your healthcare organization’s cybersecurity risk. You experience ongoing challenges around finding and retaining IT staff with expertise in information risk management. You know you’ll need staff resources to implement that new security tool, but your IT budget never stretches quite far enough to cover all of your organization’s technology needs, let alone managing cybersecurity risk.

Sound familiar?

Shiny Object Syndrome' in the security realm is often associated with a myopic focus on one critical area of weakness or vulnerability

Healthcare security leaders are often tempted to buy the “shiny new object” that promises to be the panacea to their most pressing security problems. Perhaps an audit or assessment highlighted the gap and executive management jumped all over it. Perhaps a breach or security incident became a compelling event, and the vendor’s new tool looks like a silver bullet. Vendors often encourage this line of thinking, being only too happy to make another sale.

Though new security tools can be tempting, their purchase is sometimes the result of a myopic focus on a single critical area of weakness or vulnerability. Yet the vast majority of healthcare organizations have many security gaps, spread over a wide range of areas. This is true regardless of the size of an organization’s dedicated IT staff or their information risk management budget.

When a shiny new security tool attracts your attention, how do you determine whether or not this is the best use of your resources? How do you make the case to your Board that purchasing this particular tool should be your organization’s number one priority?

The Changing Cyber Risk Landscape

All too often, healthcare security leaders are put in the position of simply reacting to the latest, headline-grabbing cyber security threats. A short time ago, cyber attackers seemed mostly intent on hacking into healthcare networks in order to steal patient data and sell it on the black market. The consequences of a data breach are far-reaching, including a loss of customer trust, penalties and settlement fees imposed by the Office for Civil Rights (OCR) for HIPAA violations, and the cost of remediation measures. A recent Ponemon Institute report estimates the average total cost of a data breach at $3.86 million. As a result, stakeholders including Board of Trustees members and consumers clamor for assurance that their healthcare providers have tools and strategies in place to prevent data breaches.

But even as data breaches continue to pose a real threat to healthcare organizations, new threats have emerged. Ransomware attacks on healthcare organizations have turned out to be just as lucrative for cyber criminals, if not more so, than selling healthcare records on the black market. The impacts of last year’s WannaCry ransomware attacks have continued to play out in healthcare organizations in the U.S. and in the U.K.

WannaCry compromised IT system availability in order to shake down healthcare providers for ransom money. But other types of emerging malware attacks – such as NotPetya – pretend to be ransomware while actually destroying critical systems and data. The increase in cyberattacks that target system availability have made IT system availability and resiliency the new cybersecurity mantra.

At the same time, new attack surfaces in healthcare organizations are attracting the attention of hackers. Network-attached medical devices – think Internet of Things (IoT) – are just as susceptible to malware and ransomware attacks as other, more traditional targets, such as the enterprise data center.

All this means that cyber risk management in a healthcare organization is a continually moving target. Cyber attackers’ motives, strategies and targets evolve quickly. By the time a new security tool comes on the market, a different threat has emerged, requiring a different approach to risk mitigation.

Given the constantly changing cyber security threat landscape, how is a CISO to respond? Is there a better way to protect your organization than being swayed by the latest, greatest vendor presentation? Is there a better way to protect your organization than yielding to Board pressure to respond to the cyber threat du jour currently making headlines?

The Big Picture: Enterprise Cyber Risk Assessment

The good news is that there actually is a better way.

And the better news is that this “better way” not only helps your organization meet HIPAA compliance requirements, it also helps your organization develop a strategic approach to enterprise-wide information risk management. It’s a deliberate and considered approach that can help guide your organization’s information risk management purchasing decisions and will strengthen your organization’s cybersecurity posture.

It begins with an enterprise-wide cyber risk assessment.

By an enterprise-wide cyber risk assessment, I’m not referring to marking off boxes on a controls checklist. I am also not referring to your latest technical testing, security gap assessment, or pen test. I’m talking about conducting a bona fide, enterprise-wide, HIPAA-compliant, security risk assessment and analysis.

What does a HIPAA-compliant security risk assessment look like?

Stay tuned. I will explore that topic in Part 2 of this three-part blog series: Panaceas, Shiny Objects and the Importance of Managing Risk in a Healthcare Environment.

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