Healthcare Data Security

Healthcare Organizations Found Not to be In Conformance with NIST CSF and HIPAA Rules

A recent study conducted by the consultancy firm CynergisTek has revealed healthcare organizations are not in conformance with NIST Cybersecurity Framework (CSF) controls and the HIPAA Privacy and Security Rules.

For the study, CynergisTek analyzed the results of assessments at almost 600 healthcare organizations against NIST CSF and the HIPAA Privacy and Security Rules.

The NIST CSF is a voluntary framework, but the standards and best practices help organizations manage cyber risks. Healthcare organizations that are not in conformance with CSF controls face a higher risk of experiencing a cyberattack or data breach. On average, healthcare organizations were only in conformance with 47% of NIST CSF controls. Conformance has only increased by 2% in the past year.

Assisted living organizations had the highest level of conformance with NIST CSF (95%), followed by payers (86%), and accountable care organizations (73%). Business associates of HIPAA covered entities only had an average conformance level of 48%. Physician groups had the lowest level of conformance (36%).

Out of the five core functions of the NIST CSF – Identify, detect, protect, respond, and recover – conformance was lowest for detect.

Even though conformance with the HIPAA Security Rule has been mandatory for the past 14 years, many healthcare organizations were found to be falling short. On average, healthcare organizations were found to be in conformance with 72% of HIPAA Security Rule requirements, which was 2% lower than last year. Critical access hospitals fared the worst with an average of 67% conformance.

Even when organizations were complying with HIPAA Rules, significant security gaps were identified, which clearly demonstrated compliance does not necessarily equate to security.

Compliance with the requirements of the HIPAA Privacy Rule was better, but there is still significant room for improvement. On average, healthcare organizations were complying with 77% of HIPAA Privacy Rule provisions. Many organizations had missing policies and procedures and improper postings. More than 60% of assessments revealed gaps in the maintenance of written policies and procedures related to the use and release of protected health information.

Conformance with the HIPAA Privacy Rule increased year over year for payers and physician groups, but declined for hospitals and health systems, falling from 94% in 2017 to 72% in 2018. CynergisTek explained this fall as most likely being due to higher numbers of assessments being performed on hospitals and health systems in 2018.

CynergisTek also found that insider breaches continue to be a major challenge for healthcare organizations. Insiders were responsible for 28% of healthcare data breaches in 2018 and, on average, those breaches took 255 days to detect. 74% of cases involved employees accessing the health records of household members, 10% involved accessing the records of VIPs that were treated at the hospital. 8% of cases involved accessing the health records of co-workers and 8% involved accessing neighbors’ health records.

Business associates were found to be a major security risk. They were involved in 20% of healthcare data breaches in 2018. CynergisTek found that in many cases, healthcare organizations were not proactively assessing their vendors, even those that are medium to high risk. The most common business associate failures were related to risk assessments, governance, and access management.

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HHS Slow to Implement GAO Health IT and Cybersecurity Recommendations

The U.S. Department of Health and Human Services has been slow to implement recommendations made by the Government Accountability Office. In total. 392 recommendations have yet to be addressed, including 42 which GAO rated as high priority.

Over the past four years, GAO has made hundreds of recommendations, but the HHS has only addressed 75% of them, 2% less than other government agencies.

The poor implementation rate was outlined in a March 28, 2019 letter from the GAO to HHS secretary Alex Azar.

GAO explained that healthcare is part of the nation’s critical infrastructure and relies heavily on computerized systems and electronic data to function. Those systems are regularly targeted by a diverse range of threat actors, so it is essential they are secured and protected from unauthorized access.

GAO drew attention to four high priority recommendations covering health IT and cybersecurity that are still outstanding.

“The four open priority recommendations within this area outline steps to ensure HHS can effectively monitor the effect of electronic health records programs and progress made toward goals; encourage adoption of important cybersecurity processes and procedures among healthcare entities; protect Medicare beneficiary data accessed by external entities; and ensure progress is made toward the implementation of IT enhancements needed to establish the electronic public health situation awareness network,” wrote GAO in the letter.

GAO explained that in March 2018, it recommended that the administrator of Centers for Medicare and Medicaid Services (CMS) should develop and implement policies and procedures to ensure entities that use claims data should evaluate the performance of Medicare service and equipment providers and ensure they have implemented appropriate security controls.

While CMS has agreed to engage a contractor to review the current data security framework and provide recommendations on specific controls and implementation requirements, GAO notes that CMS must also develop appropriate processes and procedures for implementing those controls.

Three other high priority health IT and cybersecurity recommendations have yet to be implemented.

The HHS has yet to develop performance measures that allow it to assess whether the Meaningful use program (now the Promoting Interoperability Program) is actually improving outcomes and patient safety.

GAO recommended in 2018 that the HHS and the Secretary of Agriculture should collaborate with the Department of Homeland Security and NIST and develop methods for determining the level and type of cybersecurity framework adoption required to improve the critical infrastructure of the healthcare industry. While some work has been completed in this area, GAO wrote that the HHS is still trying to identify applicable methods 12 months on.

GAO also recommended that the HHS should instruct the Assistant Secretary for Preparedness and Response to conduct all IT management and oversight processes when establishing the network and should act under the leadership of the HHS CIO. GAO notes that little has been done to enhance national public health situational awareness network capabilities that would allow officials to view real-time information about emerging health threats.

GAO explained that it is essential for these and other recommendations to be implemented promptly. Further, GAO believes that fully implementing all of its recommendations will significantly improve HHS operations.

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March 2019 Healthcare Data Breach Report

In March 2019, healthcare data breaches continued to be reported at a rate of almost one a day. 30 healthcare data breaches were reported to the HHS’ Office for Civil Rights by HIPAA-covered entities and their business associates. The March total is 11% higher than the average of the past 60 months.

HEalthcare data breaches by month

The number of reported breaches fell by 6.67% month over month and there was a 58% decrease in the number of breached healthcare records. March saw the healthcare records of 883,759 individuals exposed, impermissibly disclosed, or stolen as a result of healthcare data breaches.

healthcare records exposed by month

Causes of March 2019 Healthcare Data Breaches

The HHS’ Office for Civil Rights groups together hacking and other IT incidents such as malware and ransomware attacks. This category dominated the breach reports in March with 19 incidents reported. Hacking/IT incidents accounted for 83.69% of all compromised records (739,635 records).

There were 8 unauthorized access/disclosure incidents reported in March. 81,904 healthcare records were impermissibly accessed or disclosed. There were also four theft incidents reported, which involved a total of 23,960 records.

The biggest data breach was reported by Navicent Health – A phishing attack in which the records of 278,016 patients were potentially accessed and copied by the attackers. A similarly sized data breach was reported by ZOLL Services, which impacted 277,319 individuals. The ZOLL Services breach occurred at one of its business associates. It’s email archiving company accidentally removed protections in its network server. It is unclear whether those records were accessed by unauthorized individuals during the time the information was accessible.

Causes of March 2019 healthcare data breaches

Largest Healthcare Data Breaches Reported in March 2019

Rank Name of Covered Entity Covered Entity Type Individuals Affected Type of Breach Location of Breached Information
1 Navicent Health, Inc. Healthcare Provider 278,016 Hacking/IT Incident Email
2 ZOLL Services LLC Healthcare Provider 277,319 Hacking/IT Incident Network Server
3 LCP Transportation, Inc Business Associate 54,528 Unauthorized Access/Disclosure Email
4 Superior Dental Care Alliance Business Associate 38,260 Hacking/IT Incident Email
5 Superior Dental Care Health Plan 38,260 Hacking/IT Incident Email
6 St. Francis Physician Services Healthcare Provider 32,178 Hacking/IT Incident Network Server
7 Palmetto Health Healthcare Provider 23,811 Hacking/IT Incident Email
8 Gulfport Anesthesia Services, PA Healthcare Provider 20,000 Theft Other
9 Women’s Health USA, Inc. Business Associate 17,531 Hacking/IT Incident Desktop Computer, Email
10 Verity Medical Foundation Healthcare Provider 14,894 Hacking/IT Incident Email

 

Location of Breached Protected Health Information

Email incidents dominated the March 2019 healthcare data breach reports with 12 incidents reported that involved ePHI stored in emails and/or email attachments. The vast majority of those email breaches were phishing attacks. There were 7 hacking/IT incidents involving network servers – A combination of ransomware attacks, hacks, and the accidental deactivation of security solutions.

causes of march 2019 healthcare data breaches

March 2019 Healthcare Data Breaches by Covered Entity

Healthcare providers reported the most healthcare data breaches in March with 21 reported incidents. 4 breaches were reported by health plans and there were 5 data breaches reported by HIPAA business associates.  A further three breaches had some business associate involvement.

March 2019 healthcare data breaches by covered entity type

Healthcare Data Breaches by State

Healthcare organizations/business associates based in 18 state reported data breaches in March 2019. Three data breaches were reported in each of California, Ohio, and Pennsylvania. Two breaches were reported in each of Arizona, Idaho, Maryland, Massachusetts, Minnesota, Oregon, and South Carolina. One breach was reported in each of Arizona, Connecticut, Florida, Georgia, Indiana, Mississippi, New York, and Oklahoma.

HIPAA Enforcement in March 2019

The HHS’ Office for Civil Rights did not agree any fines or settlements in March 2019; however, the Texas Department of Aging and Disability Services has agreed to a financial penalty over a 2015 data breach.

Texas approved a settlement of $1.6 million to resolve alleged HIPAA violations discovered during the investigation of an 8-year data breach that was reported in June 2015. OCR has yet to confirm the settlement publicly.

There were no HIPAA-related financial penalties agreed with state attorneys general in March 2019.

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Data Security Incident Response Analysis Published by BakerHostetler

BakerHostetler has released its fifth annual Data Security Incident Response Report, which contains an analysis of the 750+ data breaches the company helped manage in 2018.

BakerHostetler suggests there has been a collision of data security, privacy, and compliance, and companies have been forced to change the way they respond to security breaches.

In addition to federal and state regulations covering data breaches and notifications, companies in the United States must also comply with global privacy laws such as the EU’s General Data Protection Regulation (GDPR).  All of these different regulations make the breach response a complex process. The definitions of personal information and breach response and reporting requirements differ for GDPR, HIPAA, and across the 50 states. The failure to comply with any of the above-mentioned regulations can lead to severe financial penalties. It is therefore of major importance to be prepared for breaches and be able to respond as soon as a breach is discovered.

This has led many companies to create committees to help manage data breaches, which include stakeholders with expertise in each of the above areas.

Most Common Causes of Data Breaches

An analysis of 2018 incidents shows phishing remains the most common cause of data breaches, accounting for 37% of all incidents managed by the law firm in 2018. The most common type of phishing attack seeks Office 365 credentials. 34% of phishing attacks in 2018 resulted in an Office 365 account being accessed by the attacker.

  1. Phishing Attacks – 37%
  2. Network Intrusions – 30%
  3. Accidental Disclosures – 12%
  4. Lost/stolen devices and records – 10%
  5. System Misconfiguration – 4%

30% of successful phishing attacks saw the attackers peruse the network to find accessible data. 12% of intrusions resulted in the deployment of ransomware, and 8% resulted in a fraudulent wire transfer. In 1% of cases, a successful phishing attack resulted in the deployment of malware other than ransomware.

55% of successful attacks occurred as a result of a mistake by employees, 27% were due to a non-vendor unrelated third party, 11% were due to a vendor, 5% of attacks involved a malicious insider, 3% were due to a non-vendor related third party, and 2% were due to an unrelated third party.

Incident Response, Investigation and Recovery

In 2018, 74% of breaches were discovered internally and 26% were identified by a third-party.

The average time to detect a breach across all industry sectors was 66 days. It took an average of 8 days to contain the breach and 28 days for a forensic investigation to be completed. The average time to issue notifications was 56 days.

Healthcare data breaches took an average of 36 days to discover, 10 days to contain, 32 days to complete a forensic investigation, and 49 days to issue notifications. Healthcare data breaches required an average of 5,751 notification letters to be sent.

There was an increase in investigations by OCR and state Attorneys General in 2018. 34% of breaches resulted in an investigation by an Attorney General and 34% were investigated by OCR. Out of 397 breach notifications issued, 4 lawsuits were filed.

There has been an increase in the use of forensic investigators following a breach. 65% of breaches involved some kind of forensic investigation compared to 41% of incidents in 2017. The average cost of a forensic investigation was $63,001 and $120,732 for network intrusion incidents.

The average ransom payment that was paid was $28,920 and the maximum was $250,000. In 91% of cases, payment of the ransom resulted in the attacker supplying valid keys to decrypt files.

70% of breaches required credit monitoring services to be offered, in most cases due to the exposure of Social Security numbers.

BakerHostetler also notes that following a data breach there is often an increase in access right requests. It is therefore important for companies to have established and scalable access right request processes in place to ensure they can cope with the increase following a security breach.

Interactive Data Breach Notification Map

Healthcare organizations are required to comply with the HIPAA Breach Notification Rule which requires breach notification letters to be issued to affected individuals within 60 days of the discovery of a breach of PHI.

States have also introduced their own breach notification laws, which differ from HIPAA and may, in some cases, require notifications to be issued more rapidly. To help companies find out about the breach notification requirements in each state, BakerHostetler has compiled an interactive data breach notification map.

Using this interactive tool, organizations can find out about the breach reporting requirements in each state. The interactive data breach notification map can be viewed on this link.

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OCR Issues Warning on Advanced Persistent Threats and Zero-Day Exploits

The HHS’ Office for Civil Rights has raised awareness of the risk of advanced persistent threats and zero-day exploits in its spring cybersecurity newsletter.

Healthcare organizations are attractive targets for hackers due to quantity of sensitive data they store. Individual’s protected health information is highly valuable as it can be used for many different purposes, including identity theft, tax fraud, and gaining access to medical services. Sensitive information about medical conditions can also be used to blackmail individuals.

Healthcare organizations also store research data, genetic data, and data from experimental treatments, all of which are of great value cybercriminals. The information can be used by foreign governments to drive innovation.

There are many techniques that hackers use to break through defenses and silently gain access to networks, two of the most serious threats being advanced persistent threats and zero-day exploits.

An advanced persistent threat (APT) is a term used to refer to repeated cyberattacks that attempt to exploit vulnerabilities to gain access to information systems. These attacks are often sophisticated, but even relatively simple attacks are dangerous due to their persistence.

The aim of the attacks is to stealthily gain access to information systems and steal information over a long period of time. “Advanced” comes from the techniques used to access networks and remain undetected, such as the use of malware. “Persistent” refers to the length of time that systems are accessed and information is stolen. Several APT groups have succeeded in gaining access to healthcare IT systems in the United States and have used that access to steal sensitive patient information and propriety healthcare data.

Zero-day exploits – or zero-day attacks – involve the use of previously unknown vulnerabilities to attack organizations. By their very nature, these types of attacks can be difficult to prevent. Since the vulnerabilities are only known to hackers, no patches exist to correct the flaws.

Oftentimes, vulnerabilities are discovered as a result of them being exploited. Patches are promptly released to correct the flaws, but hackers will continue to take advantage of the vulnerabilities until systems are patched. It is therefore essential to apply patches promptly and ensure that all operating systems and software are kept up to date.

Once a zero-day vulnerability is publicly disclosed it doesn’t take long for an exploit to be developed. Oftentimes, exploits for recently discovered vulnerabilities are developed and used in attacks within days of a patch being released.

If patches cannot be applied promptly, such as if extensive testing is required, it is important to implement workarounds or other security controls to prevent the vulnerabilities from being exploited. The use of encryption and access controls can help to ensure that even if access to a network is gained through the exploitation of a vulnerability, damage is minimized.

OCR has warned of the danger of combination attacks involving APTs and zero-day exploits, such as the use of the NSA’s EternalBlue exploit. Within days of the exploit being made available online, it was incorporated into WannaCry ransomware which infected hundreds of thousands of computers around the world. A patch for the vulnerability that EternalBlue exploited was released by Microsoft 2 months before the WannaCry attacks. Organizations that patched promptly were protected against the exploit and WannaCry.

Healthcare organizations and their business associates can Improve their defenses against zero-day exploits and APTs by implementing measures outlined in the HIPAA Security Rule. OCR has draw attention to the following requirements of the Security Rule which can help prevent and mitigate zero-day exploits and APTs:

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Study Reveals Health Information the Least Likely Data Type to be Encrypted

Health information is the least likely data type to be encrypted, even though health information is highly valuable to cybercriminals, according to the Global Encryption Trends Study conducted by the Ponemon Institute on behalf of cryptographic solution provider nCipher.

The study was conducted on 5,856 people across several industry sectors in 14 countries, including the United States. The aim of the study was to investigate data encryption trends, the types of data most likely to be encrypted, how extensively encryption has been adopted to improve security, and the challenges faced by companies when encrypting data.

The study shows the use of encryption has steadily increased over the past four years. 45% of surveyed organizations said they have an overall encryption plan or strategy that is applied across the whole organization. 42% said they have a limited encryption plan or strategy, with encryption only used on certain applications and data types. 13% of respondents said they do not use encryption at all on any type of data.

The use of encryption varies considerably from country to country. Germany leads the world with the highest prevalence of encryption, followed by the United States, Australia, and the United Kingdom. Out of the 14 countries represented in the survey, the Russian Federation and Brazil had the lowest prevalence of encryption. 65% of companies in the United States had an overall encryption plan that was consistently applied across the whole organization.

The industries that had the highest prevalence of encryption were tech & software (52%), financial services (50%), and the healthcare and pharmaceutical industries (49%).

Encryption technology varied considerably and there was no single technology that dominates in organizations. The most common uses of encryption were for Internet communications, databases and laptop hard drives.

The main reasons for implementing encryption, cited by 54% of respondents, were to protect sensitive intellectual property and customers’ personal information.

The types of data most commonly encrypted are payment-related data (55%), financial records (54%), HR/employee data (51%), and intellectual property (51%). Health information was the least likely type of data to be encrypted. This is surprising, given the value of healthcare data to cybercriminals and the harm that can be caused should information fall into the wrong hands. Only 24% of respondents said health data was routinely encrypted.

Organizations looking to encrypt data face several challenges. The biggest challenge which was faced by 69% of respondents was identifying all sensitive data on the network. The initial implementation of encryption was a major challenge for 49% of respondents and 32% of respondents said they faced problems classifying which data they should encrypt.

One of the biggest encryption headaches is key management. Respondents were asked to rate key management on a pain scale of 1-10. 61% of respondents said key management was very painful and managing keys was a major challenge.

The main reason why key management is difficult is a lack of clear ownership of the key management function, a lack of skilled personnel, and isolated or fragmented key management systems.

Various key management systems are used by organizations, the most common being formal key management policy (KMP), followed by formal key management infrastructure (KMI) and manual process.

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Concerns Raised About the Sharing of Health Data with Non-HIPAA Covered Entities via Apps and Consumer Devices

Earlier this month, the eHealth Initiative Foundation and Manatt Health issued a brief that calls for the introduction of a values framework to better protect health information collected, stored, and used by organizations that are not required by law to comply with Health Insurance Portability and Accountability Act (HIPAA) Rules.

Health information is increasingly being collected by a wide range of apps and consumer devices. In many cases, the types of data collected by these apps and devices are the same as those collected and used by healthcare organizations. While healthcare organizations are required to implement safeguards to ensure the confidentiality, integrity, and availability of health information and uses and disclosures of that information are restricted, the same rules do not cover the data if the information is collected by other entities.

It doesn’t matter what type of organization stores or uses the data. If that information is exposed it can cause considerable harm, yet this is currently something of a gray area that current regulations do not cover properly.

At the time when HIPAA and the subsequent Privacy and Security Rules were enacted, the extent to which health information would be collected and used by apps and consumer devices could not have been known. Now, new rules are required to ensure that health information is not exposed and remains private and confidential when collected by non-HIPAA covered entities.

Laws have been introduced that do extend to health data collected by apps and consumer devices, including the California Consumer Privacy Act (CCPA), but these laws only apply at the state level and protections for consumers can vary greatly from state to state.

HIPAA was updated by the HITECH Act of 2009, which does cover electronic medical records and health IT, but does not extend to apps and consumer devices. GDPR covers consumer data collected by apps and consumer devices, but only for companies doing business with EU residents.

The Brief, entitled, Risky Business? Sharing Data with Entities Not Covered by HIPAA explores the problem, the extent of data now being shared, and aims to clear up some of the confusion about when HIPAA applies to apps and consumer devices and when it does not and explores other federal guidance and regulations that has been issued by the FDA, FTC, and CMS covering mobile apps and consumer devices.

HIPAA does apply to business associates of HIPAA covered entities that provide apps and devices on behalf of the covered entity. However, if the app or device is not provided by a vendor acting as a business associate of a HIPAA covered entity, HIPAA Rules do not apply. Many healthcare organizations struggle to make the determination about whether a vendor is a business associate and if devices and apps are offered on behalf of the covered entity. The brief attempts to explain the often-complex process.

One area of particular concern is the growing number of people who are using genealogy services and are supplying companies with their DNA. Individuals are voluntarily providing this information, yet many are unaware of the implications of doing so and are unaware of the lucrative DNA market and the potential sale of their DNA profiles.

“Privacy and security in healthcare are at a critical juncture, with rapidly changing technology and laws that are struggling to keep pace,” explained Jennifer Covich Bordenick, Chief Executive Officer, eHealth Initiative Foundation. “Even as new laws like CCPA and GDPR emerge, many gray areas for the use and protection of consumer data need to be resolved. We hope the insights from papers like this help industry and lawmakers to better understand and address the world’s changing privacy challenges.”

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$1.6 Million Settlement Agreed with Texas Department of Aging and Disability Services Over 2015 Data Breach

The Department of Health and Human Services’ Office for Civil Rights has agreed to settle a HIPAA violation case with the Texas Department of Aging and Disability Services (DADS) to resolve HIPAA violations discovered during the investigation of a 2015 data breach that exposed the protected health information of 6,617 Medicaid recipients.

The breach was caused by an error in a web application which made ePHI accessible over the internet for around 8 years. DADS submitted a breach report to OCR on June 11, 2015.

OCR launched an investigation into the breach to determine whether there had been any violation of HIPAA Rules. On July 2015, OCR notified DADS that the investigation had revealed there had been multiple violations of HIPAA Rules.

DADS was deemed to have violated the risk analysis provision of the HIPAA Security Rule – 45 C.F.R. § 164.308(a)(1)(ii)(A) – by failing to conduct a comprehensive, organization-wide risk analysis to identify potential risks to the confidentiality, integrity, and availability of ePHI.

There had also been a failure to implement appropriate technical policies and procedures for systems containing ePHI to only allow authorized individuals to access those systems, in violation of 45 C.F.R. § 164.308(a)(4) and 45 C.F.R. § 164.312(a)(1).

Appropriate hardware, software, and procedural mechanisms to record and examine information system activity had not been implemented, which contributed to the duration of exposure of ePHI – A violation of 5 C.F.R. § 164.312(b).

As a result of these violations, there was an impermissible disclosure of ePHI, in violation of 45 C.F.R. § 164.502(a).

The severity of the violations warranted a financial penalty and corrective action plan. Both were presented to the State of Texas and DADS was given the opportunity to implement the measures outlined in the CAP to address the vulnerabilities to ePHI.

The functions and resources that were involved in the breach have since been transferred to the Health and Human Services Commission (HHSC), which will ensure the CAP is implemented.

The State of Texas presented a counter proposal for a settlement agreement to OCR which will see the deduction of $1,600,000 from sums owed to HHSC from the CMS. The settlement releases HHSC from any further actions related to the breach and HHSC has agreed not to contest the settlement or CAP.

The settlement has yet to be announced by OCR, but it has been approved by the 86th Legislature of the State of Texas. This will be the first 2019 HIPAA settlement between OCR and a HIPAA covered entity.

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Healthcare Industry Ranks 8th for Cybersecurity but Poor DNS Health and Endpoint Security of Concern

Through compliance with HIPAA, healthcare organizations have achieved a baseline standard of security, but there is still plenty of room for improvement and healthcare cybersecurity is at best mediocre.

The 2019 Healthcare Cybersecurity Report from Security Scorecard revealed the healthcare industry ranks 8th for cybersecurity out of the 18 industry sectors that were studied for the report.

The worst aspects of security for the healthcare industry were DNS health and endpoint security, where the industry ranked 13th and 12 th respectively.

Without proper DNS security measures in place, attacks could take place in which DNS records are changed. Such an attack would allow cybercriminals to route web traffic to fraudulent websites where credentials could be harvested. The US Department of Homeland Security’s Cybersecurity and Infrastructure Agency (CISA) issued a warning about this attack method in January 2019.

Endpoint security is another big concern. In healthcare, employees use a wide range of different types of devices to gain access to healthcare networks, which introduces risks and many healthcare organizations are struggling to address those risks effectively. Security Scorecard cites the 2018 HIMSS Cybersecurity Report which revealed 27.5% of healthcare employees surveyed thought there were too many endpoints in use, which was seen to be one of the biggest barriers to remediating and mitigating cybersecurity incidents.

The one area of apparent strength is network security, where the healthcare industry ranked 5th out of 18. The relatively high score in this area is not necessarily as good as it first appears. The high position means healthcare organizations are protecting the network perimeter through the use of firewalls and are segmenting their networks to limit access to devices and data in the event of a perimeter breach.

Security Scorecard notes that the network security and endpoint security scores suggest the healthcare industry is adopting an “eggshell security model” which means the perimeter controls are strong, but they are being used to defend a particularly soft and vulnerable internal network. If the perimeter is breached, insufficient controls are present to limit the harm that can be caused.

The other areas assessed for the report were application security and patching cadence, where healthcare was deemed mediocre with scores of 8/18 and 10/18 respectively. The application security score was relatively good, but Security Scorecard warned that the high number of applications used in healthcare creates multiple exploitable vectors to attack and the increasing use of networked medical devices could be placing data at risk.

Patching of known vulnerabilities is relatively slow. Patches are delayed to avoid system and application downtime and because they cause a significant increase in system resources. However, delays in patching leave organizations vulnerable. Many attacks occur within a few days of patches being released.

“The risk of ePHI exposure and unauthorized access is an increasing trend year after year,” said Fouad Khalil, VP of Compliance at Security Scorecard. “Healthcare organizations must adopt continuous assurance practices to maintain compliance and adequately protect data… Poor cybersecurity practices cannot be taken lightly.”

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