Panaceas, Shiny Objects and the Importance of Managing Risk in a Healthcare Environment – Part 3

Is there a more challenging position anywhere in information security than that of a healthcare organization’s cyber risk management leader? If there is, I can’t think of what it would be. Whether your title is CISO, CSO, CTO, CIO or some variation thereof, the task is daunting.

As we mentioned in Part 1 of this series, healthcare as an industry has a huge target on its back. Cyber attackers focus on healthcare not only because patient information is valuable, but also because patient lives are at stake. That can make threats such as ransomware attacks more effective. Cyber attacks in other industries – banking, for example – can have devastating financial consequences, but people’s lives aren’t generally at risk, as they are in healthcare.

At the same time, healthcare IT environments are exceedingly complex, which makes managing information security that much more complicated. The healthcare IT ecosystem typically includes dozens – if not hundreds – of applications, including the electronic health record (EHR) system, administrative and operational applications (scheduling, patient tracking, billing, claims, insurance and payer systems and interfaces), clinical applications (patient monitoring systems, radiology information systems, lab results reporting, clinical decision support, patient portals, etc.) and others too numerous to mention.

On top of this, add the countless devices that connect to a healthcare organization’s network, from the desktop computer at the registration desk, to the tablet the physician or nurse uses, to the smart infusion pump at the patient’s bedside, to BYOD devices like the smartphone a patient uses to access lab results through a patient portal.

Enterprise-wide Cyber Risk Assessment

Because of this complexity, no single “shiny object” or new security tool will be sufficient to mitigate all of the critical information security risks in a healthcare environment. As we discussed in Part 2 of this series, the only way to approach cyber risk management in a complex healthcare organization is to begin with a comprehensive, OCR-quality, security risk assessment and analysis.

Healthcare organizations must conduct this type of analysis in order to be HIPAA-compliant. But just as important is the fact that healthcare organizations cannot begin to develop a meaningful and effective cyber risk management program without first gathering the information that a comprehensive risk analysis provides.

As mentioned in the previous post, a security risk analysis essentially boils down to three tasks:

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

The HIPAA Security Rule, OCR Guidance, and resources developed by NIST provide plenty of details on how to properly conduct a risk assessment and complete these tasks. These resources are freely accessible on the internet. In theory, any healthcare organization could use these resources to conduct and complete an OCR-quality risk analysis without any outside support. However, that’s easier said than done.

Task 1: Identifying Risk

Risk identification begins with creating an information asset inventory that documents each asset that creates, receives, maintains or transmits electronic Protected Health Information (ePHI). This includes not just the obvious choices, such as laptops, servers, and enterprise applications, but also less obvious choices, including medical devices, backup media, and nonclinical, internet-connected assets such as building management applications and networks.

As noted in my previous post, creating an asset inventory is only the first step in risk identification. Risk has three components: an asset, a threat and a vulnerability. OCR guidance specifies that healthcare organizations must identify and document threats and vulnerabilities to each asset, in addition to creating an inventory of information assets.

Task 2: Rating Risk

Once you have exhaustively inventoried every aspect of risk – including every asset, and each of the threats and vulnerabilities associated with each asset – the HIPAA Security Rule and subsequent OCR guidance specifies that you must also estimate the likelihood (probability) and impact (magnitude of loss) of potential harm from each asset/threat/vulnerability combination. This is the risk rating.

NIST provides guidance for these tasks. NIST SP 800-30, Appendix G, includes several examples of assessment scales related to threat event likelihood. Appendix H, in the same publication, offers examples of scales for measuring impacts.

Task 3: Prioritizing Risk

After all information assets have been identified; after all potential threats and vulnerabilities have been documented; and after the likelihood and impact of each asset/threat/vulnerability combo has been calculated, each asset/threat/vulnerability combination will have an assigned risk rating.

As part of the cyber risk assessment/analysis process, every healthcare organization should establish a risk threshold. Establishing a risk threshold is part of the information security governance process. The risk threshold will be unique to the organization and will take into account the organization’s unique risks and resources. For example, using the 25-point scale, one organization might establish 15 as their threshold, meaning that any risk with a rating of 15 or below falls into the acceptable risk category, and will not be a priority with respect to mitigation.

A comprehensive information security risk analysis, combined with the organization’s established risk threshold, enables a healthcare organization to make informed, strategic decisions about which cyber security risks require urgent mitigation versus those that can be put on the “back burner” until more resources are available.

The Bottom Line

Conducting a comprehensive risk assessment is necessary for both HIPAA compliance and for establishing the foundation for a healthcare organization’s enterprise cyber risk management system (ECRMS). It is challenging, but not impossible, for a healthcare organization to conduct this analysis using only internal resources and guidance that is available on the internet.

Alternatively, healthcare organizations can use the specialized solutions and professional expertise to quickly and efficiently conduct a comprehensive cyber risk analysis. Because ultimately, completion of the analysis is only the first step. The sooner a comprehensive security risk analysis is completed, the sooner a healthcare organization can begin addressing vulnerabilities and mitigating high priority risks.  

Read more in this series:

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

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

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Medical Device Security and CIO Insomnia

During a conversation over drinks with a number of CIOs at a recent healthcare conference, I discovered that the number one concern that keeps most healthcare executives up at night is the security of their medical devices. That was somewhat unexpected, especially following press-grabbing headlines last year about ‘WannaCry’ and other ransomware attacks rendering a large part of the British NHS and other health systems useless for several weeks or months.

Reason 1: Management

Part of their concern is that medical devices are not typically managed by hospital IT (overseen in most cases by the CIO) but by clinical / biomedical engineering staff who power on and attach devices to hospital networks but have little understanding of the cybersecurity risks that are created by connecting an unprotected medical device to the hospital business clinical network. Connected medical devices can by-and-large be compromised easily, used as a foothold on hospital networks, or re-programed to execute patients or hold them to ransom.

This is not fiction! It has been demonstrated numerous times at security conferences most recently by McAfee at BlackHat and Defcon in Las Vegas last month. New Zealand ethical hacker Barnaby Jack started the trend of exposing medical devices vulnerabilities, when in 2011 at the MacAfee Focus Conference he demonstrated a hack of a wireless insulin pump causing the pump to deliver its entire reservoir of insulin into a mock patient. In 2012 he followed this performance up with a hack of a Pacemaker causing the device to administer an 815volt shock directly to the heart of the mock patient. Both demonstrations would have been fatal to a real patient and that might explain why in 2007 Vice President Dick Cheney had the wireless interface disabled to his own pacemaker at the insistence of Doctors and the US Secret Service. Jack demonstrated the ease at which a patient could be harmed or executed once their Implantable Medical Device or IMD had been hacked. Others followed at subsequent security conferences with hacks of network-attached infusion pumps, reprogramming the device to give a continuous maximum dose of Morphine till the reservoir was empty and the patient likely dead.

Reason 2: Lack of Security

The CIOs second concern is that medical devices have almost no built-in security found on a typical workstation or laptop and cannot readily be patched or upgraded. Nor can security tools and supplicants like anti-malware or a host firewall be installed as the limited capacity of devices will not support the additional memory or processing requirements needed.

To compound these issues, medical device manufacturers are notoriously reluctant and slow to release patches for their devices even when known security vulnerabilities have been discovered. This has resulted in some high profile shaming of manufactures as in the case of Muddy Waters Capital, an Options Trader, against St Jude Medical and the first ever FDA recall of a medical device as a result of the public disclosure. Would the Food and Drug Administration (FDA) have acted if it weren’t for the very public disclosure? It’s hard to tell. Would St Jude Medical have spent any time fixing known security vulnerabilities in some of its pumps? Based upon past performance, it’s highly unlikely. In fact, that was the reason for Muddy Waters penetration test in the first place, thus driving down the share price of St Jude Medical stock, allowing Muddy Waters to profit from its options trades.

The fact of the matter is that most medical devices unless afforded extra layers of protection and defense-in-depth security, are extremely vulnerable to cyberattack. Especially if connected to the main hospital network, let alone allowed to talk to the Internet.

Why are Medical Devices so Vulnerable to Attack and Compromise?

Medical devices take 5 to 6 years to go through testing and clinical trials before they receive FDA approval. The same is true in most other countries. That means that brand new devices arriving in hospitals today were designed at least 5 or 6 years ago using technology that was available at the time. Anyone connecting their 2012 era Windows computer to the Internet tomorrow without any security software or updates would more than likely be compromised inside 10 minutes, yet that’s what we do with medical devices. Only with medical devices, we use them not to surf the web or check email, but to monitor and treat patients - and in some cases keep them alive. That’s where unmitigated risks surface that results in CIO insomnia.

The HIPAA Security Rule (45 CFR (§164.308(a)(1)(ii)(A)&(B) requires a Risk Analysis and ongoing Risk Management be conducted of any and all devices that create, maintain, transmit, or receive ePHI or other sensitive data. Yet most hospitals don’t even have an accurate inventory of their medical device assets so how can they possibly assess their risks? The identification and profiling of medical devices has not been easy for hospitals, most of which have had to rely upon labor-intensive ad-hoc manual discovery processes. New tools and services from IoMT / HIoT vendors in the space that can identify and profile medical devices is beginning to change this however. A full asset inventory and medical device profile can now be exported from these tools and entered into enterprise risk analysis tools to perform compressive risk analysis to meet the very strict requirements of OCR and HIPAA.

The concern however is a lot deeper than mere HIPAA Compliance and the protection of PHI. Patient safety has become a major worry for healthcare providers where changes to the integrity and programming of medical devices can have far reaching effects. Hackers have already demonstrated the removal of safety limits and have over-written calibration data and dosages and changed drug libraries. Not only is the integrity of medical devices a growing concern but also their resiliency. Most devices will crash or blue screen when a simple virus or multi-cast traffic appears on the subnet. In particular, device availability for patient telemetry systems is critical to alert care staff to patient Codes or other conditions where speedy action on their behalf is required to save a life. Integrity and availability attacks are far more concerning than confidentiality attacks against PHI, and is where the real damage can be done.

To date, the OCR has only issued written guidance on the risk analysis of medical devices containing PHI, although audits show that OCR is beginning to take a broader look at all medical devices regardless of whether they create, receive, store or transmit PHI. The FDA continues to issue guidance, NCCoE and NIST have written a guide to secure medical infusion pumps resulting in NIST Special Publication 1800-8, and the Cloud Security Alliance (CSA) and Open Web Application Security Project (OWASP) recently joined forces to publish a revised Medical Device Deployment Guide. The fact remains however, that numerous medical devices are extremely vulnerable and are not being adequately managed from a risk perspective.

The average cost of a data breach according to Ponemon is $3.8 million. The damage and impact to a hospital’s reputation following a medical device attack resulting in patient death is pretty much unlimited. This may sound a little far-fetched but a recent study by the University of California Cyber Team found that several hospitals had self-reported adverse events from compromised healthcare infrastructure cybersecurity events, like ransomware, malware, or compromised EHRs. The study found that adverse events impacted between 100 and 1,000 patients. Furthermore, the 80 percent of survey respondents that reported risks in medical devices, is way higher than what the FDA reports.

Risk Management

Once identified, risks to critical systems should be addressed immediately. When remediation or retirement of a medical device is not possible, effective compensating security controls should be implemented to isolate and protect the device from attack and compromise. Many of the larger hospital systems are turning to micro-segmentation of their medical device network assets using Cisco TrustSec or other tools to essentially white-list network communications to and from each medical device and drop all other traffic. GE Health and Unisys do this by routing all medical device traffic through proxy servers. Others have segmented their medical device VLANs by use of internal firewalls. These solutions all increase the complexity of networks and leave many smaller hospital systems with tight budgets and limited capabilities out in the cold.

What’s being done to harden medical devices and prevent them from being hacked?

Guidance (and its only guidance to date) has been published by the FDA, NIST, NCCoE, CSA/OWASP and others to improve the deployment and security of medical devices. The onus however is squarely being placed upon healthcare providers to secure the medical devices they procure and utilize. At the same time manufacturers are being pressured to improve the security design of their devices and now have to perform a risk analysis of medical devices before FDA approval. But with a 5 to 6-year development cycle, the results of ‘improved security by design’ may take many years to reach hospitals and patients. With a 15 to 20-year lifespan for many medical devices, the security problem is not about to go away any time soon. That means hospitals need to implement compensating security controls immediately and keep them there for the foreseeable future.

Somewhat alarmingly however, a recent Ponemon Report on Medical Device Security showed that despite known vulnerabilities “roughly one third of device makers and healthcare delivery organizations (HDOs) are aware of potential adverse effects to patients due to an insecure medical device, but despite the risk only 17 percent of device makers and 15 percent of HDOs are taking significant steps to prevent such attacks.”

Healthcare IoT and the Internet of Medical Things currently presents perhaps the single biggest open back door to securing healthcare the world over. 

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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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Security Tools and SaaS

With between 45 and 65 different security vendors' tools in the average hospital CISO's tool box, healthcare providers need to make sure that third-party tools work well together and do not create unwanted complexity or introduce their own vulnerabilities.

Smaller providers in particular should look to partner with service providers to procure and consume expert security services rather than continue to pour money into the management of in-house tools. Most simply can no longer afford to attract and retain the levels of cybersecurity staff needed to defend against sophisticated attacks or to maintain an adequate level of risk management and compliance.

Security-as-a-Service (SaaS) is helping to reset the imbalance between attacker and defender, and when healthcare security teams are outnumbered 5 to 1, they need all the help they can get!

This was the subject of my recent video interview with HIMSS.

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Shiny Objects

Security leaders all too often succumb to the distraction of a new shiny object that promises to be the panacea to all their security problems. Vendors encourage this line of thinking happy to make another sale and to have a new customer. What makes things worse is that a focus on CapEx budgets at most organizations to buy and implement more tools encourages this behavior when really an annual service may be a far cheaper, better, and faster solution to meet organizational needs.

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

'Shiny Object Syndrome' in the security realm is often associated with a myopic focus on one critical area of weakness or vulnerability. Perhaps an audit or assessment highlighted the gap and Executive Management jumped all over it. Perhaps a barrage of vendors telling you that you must have something in a particular space wore the CISO down, but be assured that security gaps are usually many, and are usually spread across a wide range of areas even for the most well-staffed and best-funded security departments.

Understanding Risk

Before rushing to implement solutions and being distracted by shiny objects, first make sure you have a comprehensive and holistic understanding of Digital and Integrated Risk as part of the organization's overall business enterprise risk strategy. Think about new areas of digital risk such as IoT that may not have been included in your last security audit or compliance assessment. Think about new business offerings and the strategic IT plan and how that may introduce weaknesses to the cyber defenses you have already put in place. And remind yourself that compliance is just one side of the CIA triangle that CISOs are responsible for.

Attacks against the Availability of IT systems is on the rise - just look back to the recent WannaCry and Not Petya attacks. The damage was far greater monetarily and reputationally  than a fine or slap on the wrist for a confidentiality breach. With the rise in BotNet scale and sophistication and their increasing use by cyber criminals and state actors to distract or execute attacks, protecting the availability of data and systems will become far more important, if in fact it isn't already. Just ask Maersk or the British National Health Service!

First identify ALL assets. That includes IoT devices that are network attached, could be network attached but aren't currently, or contain sensitive data. This includes hospital medical devices and building management systems - even if they are on their own VLANs. Unless they are on air-gapped networks or are securely segmented using firewalls or Cisco ISE/TrustSec then they can be easily attacked and usually have little to no defenses. Just ask Cisco Talos which has been conducting extensive testing and hacking of building management systems over the past year. How embarrassing would it be to have to report to the CEO that an attack against the enterprise SAN was executed from a hacked office thermostat?

Use new discovery tools to identify IoT assets. New services from the likes of CyberMDX, CloudPost, ZingBox and others will identify medical devices, device types, software versions and VLAN location via passive observation of biomedical network traffic without threatening a device. Active and passive scanning of business networks will identify traditional assets. IRM tools like IRM|PRO from Clearwater Compliance and others can consume scan data and combine with other information to perform full Risk Analysis, as well as HIPAA security and privacy compliance or NIST framework assessment.

Risks need to have 3 components: An Asset, a Threat and a Vulnerability



Threats come in 4 categories according to NIST: Accidental, Adversarial, Structural or Environmental

Risk = Likelihood * Impact

Many if not most IRM tools use a 25 point scale to evaluate risk, such that a risk appetite can be agreed with the board of typically 15 (or lower for more mature or risk adverse organizations) and any identified risk above that threshold needs to be dealt with. Risks are typically dealt with via remediation, eradication, transfer, or by compensating controls. Once identified, risks should be prioritized and entered into a risk register and remediation plans drawn up.

Overall Risk
Impact	Disastrous (5)	Low	Medium	High	High	Critical
	Major (4)	Low	Medium	Medium	High	High
	Moderate (3)	Low	Low	Medium	Medium	High
	Minor (2)	Low	Low	Low	Medium	Medium
	Insignificant (1)	Low	Low	Low	Low	Low
		Rare (1)	Unlikely (2)	Moderate (3)	Likely (4)	Almost Certain (5)
	Likelihood

Clearwater uses a 25 point scale from zero to 25 as do many other leaders in the IRM space.

New Tools

Before investing in a new tool, figure out how long its going to take to put that tool into production and what level of effort it will take to get there. Till that tool goes live its nothing more than expensive shelf-ware and could become a thorn in your side if implementation proves to be longer than the board or executive team's patience.

Many security tools can require upwards of 2 years to fully implement and take their place in the defensive line up. According to CIO Magazine the average CISO tenure is now 17 months. Ponemon places it at 2.1 years. Either way, your 2 year project is unlikely to get from PO to production implementation before you move on to the next opportunity or challenge, so what does that say for the prospects of eventual completion under a different security leader? More importantly, how will your efforts been seen in hindsight - as a success or failure, especially if you aren't there to see it through?

SaaS - Would a Security Service be Better?

The nice thing about security-as-a-service is that if it begins to no longer meet your changing requirements or you fall out of love with it, then you simply part company at the end of the contract and fire-up an agreement with a competitor. It allows you to have the best protection you can afford each year and not get stuck with something out of date.

Procuring and implementing tools gets you locked into a multi-year marriage often with a spouse you have never met before. Depending on your depreciation schedules you could be stuck for 5 or 10 years. Whats-more, you will not be defended by the new tool till you have figured out how to use it and how to get it to production.

SaaS makes particular sense for smaller companies that may be resource-constrained by the number and caliber of security staff they can attract and retain in an increasingly highly competitive job market. It also makes great sense where a significant risk has been identified and where no compensating security controls can be leveraged to reduce risk exposure for the period it takes to procure, build, test and implement a new tool. When you absolutely have to have something now, a service will generally be a much more immediate fix.

More About Shiny Objects

Shiny objects may be OK when we are talking about a SaaS based service, but their shininess is very much dependent upon a thorough understanding of a solid and comprehensive risk analysis before the business can justify service procurement.

Most organizations have a hard enough time conducting a proper risk analysis let alone avoiding the distractions of shiny objects. No wonder then that so many fail.

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Hacking Healthcare Live: Bits and Bytes Meet Flesh and Blood

Possibly one of the BEST EVER demos at RSA of all time for anyone in the medical space. Watch a live simulated medical device hack as an unsuspecting ER doctor faces the reality of practice in a brave new world of insecure technologies and vulnerable patients.

Doctors Christian Dameff MD and Jeff Tully MD from the University of California Health System are joined by Josh Corman from I Am The Cavalry to demonstrate what can happen when a medical device attached to a an ER patient is hacked.

Healthcare cybersecurity is in critical condition. This session takes you to the front-line of efforts to save lives threatened by ransomware and runaway pacemakers.

Learning Objectives:
1: Understand how recent attacks and device vulnerabilities threaten patient lives.
2: Explore the recommendations of the Healthcare Industry Cybersecurity Task Force.
3: Witness a doctor undergo a live clinical simulation of a hacked medical device.

Speakers
Dr. Christian Dameff, Emergency Physician and Clinical Informatics Fellow, University of California San Diego
Dr. Jeff Tully, Anesthesiologist and Pediatrician, University of California Davis
Josh Corman, CSO/Founder, PTC / I am The Cavalry

Hacking Healthcare Live: Bits and Bytes Meet Flesh and Blood from the 2018 RSA Conference.

This video demonstration starts at 0:30 and runs for approximately 45 minutes.

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2018 Annual Cybersecurity Report

Cisco today released it's 2018 Annual Cybersecurity Report providing a freshly updated view into the current techniques that adversaries use to elude defenses and evade detection, along with insights and recommendations designed to help organizations and users defend against attacks.

The report is based upon a study conducted by Cisco of 3600 Chief Information Security Officers (CISOs) and security industry leaders from 26 countries.

This year’s report findings show a maturing, more sophisticated tradecraft by attackers. Case in point: adversaries are increasingly embracing encryption – meant to enhance security – to conceal command-and-control activity. The Cisco Talos threat research team reports that 50 percent of global web traffic was encrypted as of October 2017, a 12 percent volume increase from November 2016. Cisco also observed a more than threefold increase in encrypted network communication used by inspected malware samples during that time. As the volume of encrypted global web traffic grows, adversaries are broadening their use of encryption as a way to mask command-and-control activity, providing them more time to operate and inflict damage sight-unseen.

The evolution of ransomware was another of the most significant threat developments in 2017. By introducing network-based ransomware worms, attackers have eliminated the need for human interaction in launching ransomware campaigns. They also changed the game from pursuing ransom to the outright destruction of systems, data and operations. We all saw these rapid-moving, network-based attacks with WannaCry and Nyetya, and Cisco expects more automated crypto-worm activity in the year ahead.

The report report spotlights how adversaries are evolving their approaches to exploit new technology security gaps, particularly in IoT devices which are often exposed because they were deployed improperly or left open intentionally for convenience. This includes the growing number of medical devices in hospitals and other healthcare delivery sites, which are often not patched or maintained once purchased.

See the full report for additional perspectives and what defenders can do to to set the security bar higher.

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New Zealand Healthcare - Just Keeping its Head Above Water!

New Zealand Healthcare - Just keeping its head above water.  Photo: Hamish Clark.

Securing the delivery of healthcare services in New Zealand faces many of the same challenges as in other mixed public / private health systems. Chronic under-funding of the public health system by government austerity measures is putting pressure on a system already overloaded. Net immigration to New Zealand is combining with a rapidly aging population that is living longer, and contributing to increased patient numbers and demand for services. Hospital administrators have been forced to make tough decisions to prioritize what little resources are available to only the most critical of patients. The result is that many elective surgeries especially for the elderly are in decline and little funding remains to secure and defend hospitals from cyber attack.

As a result of the crisis in the public health system and waitlists approaching a year for patients requiring surgery, those who can afford it, are switching to private healthcare delivery and health insurance. The overall percentage of healthcare services delivered via the New Zealand public system has consequently dropped to roughly 75%. A growth in private care is picking up the rest.

Could New Zealand's Health System come crashing down?  Photo: Lindsey Costa.

New Zealand spends roughly a third of the per-capita expenditure on health compared with the United States. Despite this, healthcare in the country is comprehensive yet quite inefficient, and heavily reliant upon legacy models of care, including more expensive hospital treatment. A fragmented and decentralized system of twenty District Health Boards results in repetition and duplication with wasted spending on "unique solutions to common problems", disparate "stovepipe systems", and "widely different care paths for common conditions" according to a report by Deloitte.

A lack of national uniform IT and security strategy combines with moribund health IT computer systems across DHBs, and manual labour-intensive work practices by doctors and nurses to compound inefficiencies.

The reality is that much of the national health budget appears to be squandered on administrative overhead. In fact, according to the Deloitte study, "some OECD researchers have estimated that well over 2% of New Zealand’s GDP is wasted on administrative inefficiencies."

With budget deficits and almost no money to spend on security, an increasing number of people are concerned that the whole system could come crashing down. Cyber attacks on hospitals and primary care facilities in other countries have massively damaged already fragile health systems. Attacks have caused further delays to patients awaiting treatment and life sustaining operations. If nothing changes, then the same fate may befall New Zealand one day soon.

"Its not a matter of IF but WHEN a major cyber-attack will cause massive disruption to the country’s health sector" claims Scott Arrol, Chief Executive of NZ HealthIT (NZHIT).

But the security problem is not just one of sufficient funding, its also a one of prioritization and implementation of recommendations. The British National Health Service has many similarities to the New Zealand health model and is also chronically starved of resources. Out of date and out of support computer systems, combine with fragmented NHS Trusts to result in security vulnerabilities left unremediated, leaving much of the system open to attack when WannaCry struck in May last year.

According to the UK National Audit Office (NAO) more than a third of trusts in England were disrupted by the WannaCry ransomware, and at least 6,900 NHS appointments were cancelled as a result of the attack, 139 of which were considered urgent. NHS England data shows that at least 80 out of 236 trusts were affected – with 34 infected and locked out of devices. A further 603 primary care and other NHS organisations were infected by WannaCry, including 8 per cent of GP practices (595 out of 7,454).  No information has been published on the larger impact of the NHS outage including reduced patient outcomes or increased mortality, but one can only surmise that despite the best efforts of care givers, some patients were significantly impacted by the NHS's lack of security preparations.

The attack breached NHS Digital via open SMB holes in NHS firewalls and then spread quickly through thousands of unpatched Windows machines. Most infected systems ran Windows 7, but some 18% of systems were still running the no-longer supported Windows XP operating system, which went End of Life in April 2014, some 3 years earlier!

Securing healthcare delivery is not something that can be left on the side lines till next year, to a new budget, or a new administration. The potential impact on the population of a major cyber attack is too great. With the British NHS debacle as a recent example of what can happen if security is ignored, the New Zealand Ministry of Health needs to act now - before its too late!

New Zealand Healthcare steams forward with minimal security.  Photo: Stephen Crowley.

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