Healthcare Data Security

TitanHQ’s WebTitan Now Available Through Kaseya IT Complete Suite

TitanHQ has announced its DNS-based web filtering solution, WebTitan, has now been integrated into Kaseya’s IT Complete platform. The integration allows MSPs serving the healthcare industry to offer their clients an additional layer of protection against web-based threats such as phishing, malware, and ransomware.

Via Kaseya, managed service providers can access cybersecurity solutions from some of the biggest names in the industry, including Cisco, Dell, and Bitdefender. While the platform provides MSPs with a wide range of easy-to-deploy cybersecurity solutions, one notable absence was an MSP-friendly content filtering solution.

“Security is a critical service that all MSPs must deliver. Adding WebTitan to our open ecosystem of partner solutions means our customers now have even greater access to best of breed technologies to meet the needs of their business,” said Frank Tisellano, Jr., Kaseya vice president product management and design. “With growing concerns over malware, ransomware and phishing as key threats to MSP customers, WebTitan adds a highly effective layer of protection.”

A web filtering solution is a powerful tool that allows healthcare organizations to block attempts by employees to visit malicious websites, either through the clicking of hyperlinks in phishing emails, general web browsing, or redirects to malicious sites via malvertising.  A web filter is an important additional tool that helps to ensure the confidentiality, integrity, and availability of protected health information by blocking phishing attacks, malware, and ransomware downloads.

In the past month alone 10 email-based hacking incidents have been reported to OCR, with each incident resulting in the exposure of more than 500 healthcare records. The high volume of successful phishing attacks on healthcare employees highlights the need for advanced technological controls to prevent healthcare employees from visiting malicious websites and disclosing their account credentials.

Managed service providers can now access the multi-award-winning web filtering solution through Kaseya VSA and the Kaseya IT Complete Suite and deploy network-wide DNS-based web filtering in a matter of minutes, giving their healthcare clients even greater protection against malware, ransomware and phishing attacks.

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More than a Dozen Becton, Dickinson and Company Products Vulnerable to WPA2 Krack Attacks

The Department of Homeland Security (DHS) has issued a warning about certain Becton, Dickinson and Company products that have been discovered to be vulnerable to WPA2 Krack attacks. By exploiting the vulnerability, threat actors could install malware on the devices or obtain or alter patient information.

Krack – or key reinstallation – attacks take advantage of a flaw in the WPA2 protocol for securing WiFi communications. According to ICS-CERT, “The four-way hand shake traffic in the Wi-Fi Protected Access WPA and WPA2 protocol can be manipulated to allow nonce reuse resulting in key reinstallation. This could allow an attacker to execute a ‘man-in-the-middle’ attack, enabling the attacker within radio range to replay, decrypt, or spoof frames.”

In order for the flaw to be exploited, an attacker would need to be in radio range of a vulnerable device, which limits the potential for the flaw to be exploited. Exploiting the flaw is also not straightforward and requires a high level of technical skill.

Since the flaw is in the WPA2 protocol used to secure modern Wi-Fi networks, many devices were discovered to be vulnerable to attack. The flaw was first identified in October last year, and some vendors have already released patches to prevent the flaw from being exploited.

If exploited, the flaw would allow patient data to be intercepted over Wi-Fi. Becton, Dickinson and Company issued a security bulletin warning users about the vulnerability, which the company says could be exploited through an adjacent network without user privileges or user interaction.

BD has assessed its products and reports that the flaw has been addressed through third-party vendor patches through BD’s routine patch deployment process for the following products:

  • BD Alaris™ Gateway Workstation
  • BD Pyxis™ Anesthesia ES
  • BD Pyxis™ Anesthesia System 4000
  • BD Pyxis™ Anesthesia System 3500
  • BD Pyxis™ MedStation 4000 T2
  • BD Pyxis™ MedStation ESv
  • BD Pyxis™ SupplyStation
  • BD Pyxis™ Supply Roller
  • BD Pyxis™ CIISafe – Workstation
  • BD Pyxis™ StockStation System

There are issues applying patches to correct the flaw on the following products which require coordination with BD to correctly deploy the patches:

  • BD Pyxis™ ParAssist System
  • BD Pyxis™ Parx
  • BD Pyxis™ Parx handheld

BD is contacting customers who use those products to schedule a time to deploy the patches. BD has also suggested customers take other steps to reduce the risk associated with Krack:

  • Ensure the latest recommended updates for Wi-Fi access points have been implemented in Wi-Fi enabled networks
  • Ensure appropriate physical controls are in place to prevent attackers from being within physical range of an affected Wi-Fi access point and client
  • Ensure data has been backed up and stored according to your individual processes and disaster recovery procedures

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OCR Encourages Healthcare Organizations to Conduct a Gap Analysis

In its April 2018 cybersecurity newsletter, OCR draws attention to the benefits of performing a gap analysis in addition to a risk analysis. The latter is required to identify risks and vulnerabilities that could potentially be exploited to gain access to ePHI, while a gap analysis helps healthcare organizations and their business associates determine the extent to which an entity is compliant with specific elements of the HIPAA Security Rule.

The Risk Analysis

HIPAA requires covered entities and their business associates to perform a comprehensive, organization-wide risk analysis to identify all potential risks to the confidentiality, integrity, and availability of ePHI – 45 CFR § 164.308(a)(1)(ii)(A).

If a risk analysis is not performed, healthcare organizations cannot be certain that all potential vulnerabilities have been identified. Vulnerabilities would likely remain that could be exploited by threat actors to gain access to ePHI.

While HIPAA does not specify the methodology that should be used when conducting risk analyses, OCR explained in its newsletter that risk analyses must contain certain elements:

  • A comprehensive assessment of all risks to all ePHI, regardless of where the data is created, received, maintained, or transmitted, or the source or location of ePHI.
  • All locations and information systems where ePHI is created, received, maintained, or transmitted must be included in the risk analysis, so an inventory should be created that includes all applications, mobile devices, communications equipment, electronic media, networks, and physical locations in addition to workstations, servers, and EHRs.
  • The risk analysis should cover technical and non-technical vulnerabilities, the latter includes policies and procedures, with the former concerned with software flaws, weaknesses in IT systems, and misconfigured information systems and security solutions.
  • The effectiveness of current controls must be assessed and documented, including all security solutions such as AV software, endpoint protection systems, encryption software, and the implementation of patch management processes.
  • The likelihood that a specific threat will exploit a vulnerability and the impact should a vulnerability be exploited must be assessed and documented.
  • The level of risk should be determined for any specific threat or vulnerability. With a risk level assigned, it will be easier to determine the main priorities when mitigating risks through the risk management process.
  • The risk analysis must be documented in sufficient detail to demonstrate that a comprehensive, organization-wide risk analysis has been conducted, and that the risk analysis was accurate and covered all locations, devices, applications, policies, and procedures involving ePHI. OCR will request this documentation in the event of an investigation or compliance audit.
  • A risk analysis is not a one-time event to ensure compliance with the HIPAA Security Rule – It must part of an ongoing process for continued compliance. The process must be regularly reviewed and updated, and risk analyses should be performed regularly. HIPAA does not stipulate how frequently a full or partial risk analysis should be performed. OCR suggests risk analyses are most effective when integrated into business processes.

Once a risk analysis has been performed, all risks and vulnerabilities identified must be addressed through a HIPAA-compliant security risk management process – 45 CFR § 164.308(a)(1)(ii)(B) – to reduce those risks to a reasonable and appropriate level.

Guidance on conducting an organization-wide risk analysis can be found on this link (HHS)

The Gap Analysis

A gap analysis is not a requirement of HIPAA Rules, although it can help healthcare organizations confirm that the requirements of the HIPAA Security Rule have been satisfied.

A gap analysis can be used as a partial assessment of an organizations compliance efforts or could cover all provisions of the HIPAA Security Rule.  Several gap analyses could be performed, each assessing a different set of standards and implementation specifications of the HIPAA Security Rule.

The gap analysis can give HIPAA-covered entities and their business associates an overall view of their compliance efforts, can help them discover areas where they are yet compliant with HIPAA Rules, and identify any gaps in the controls that have already been implemented.

Note that a gap analysis is not equivalent to a risk analysis, as it does not cover all possible risk to the confidentiality, integrity, and availability of ePHI as required by 45 C.F.R. §164.308(a)(1)(ii)(A).

OCR offers the following example of a simple gap analysis:

Source: OCR

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Study Reveals Healthcare Industry Employees Struggling to Understand Data Security Risks

The recently published Beyond the Phish Report from Wombat Security, now a division of Proofpoint, has revealed healthcare employees have a lack of understanding of common security threats.

For the report, Wombat Security conducted a survey of more than 85,000 employees across a wide range of industry sectors. Respondents to the survey were asked questions designed to probe their knowledge of data security.

Respondents were asked about security best practices that would help them avoid ransomware attacks, malware installations, and phishing attacks and established the level of expertise at protecting confidential information, defending against email and web-based scams, securing mobile devices, working safely in remote locations, identifying physical risks, disposing of sensitive information securely, using strong passwords, and safe use of social media and the web.

Overall, the healthcare industry performed second worst for security awareness, just ahead of the hospitality industry, with the survey highlighting several areas of weakness that could potentially be exploited by cybercriminals to gain access to healthcare networks and sensitive data.

Respondents from the healthcare sector performed poorly in several areas, registering a relatively high percentage of incorrect answers related to identifying phishing emails, securely disposing of sensitive information, and protecting mobile devices and sensitive information stored on those devices.

Even though HIPAA requires healthcare employees to dispose of PHI securely, 28% of questions in this area were answered incorrectly. 27% of questions about protecting mobile devices and information were answered incorrectly, as were 26% of questions relating to the protection of confidential information, and 21% of questions on the identification of common security issues and safe use of the Internet.

Overall, respondents from the healthcare industry answered 23% of questions incorrectly, on a par with the manufacturing industry and professional services. Only hospitality industry employees performed worse. The average percentage of incorrect answers across all industry sectors was 19%.

Areas where respondents from the healthcare industry performed best were the use of safe, strong passwords and the identification and prevention of ransomware attacks, with just 12% and 10% of questions answered incorrectly.

“Our hope is that by sharing this data, infosec professionals will think more about the ways they are evaluating vulnerabilities within their organizations and recognize the opportunity they have to better equip employees to apply cybersecurity best practices and, as a result, better manage end-user risk,” said Joe Ferrara, Wombat General Manager.

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How to Defend Against Insider Threats in Healthcare

One of the biggest data security challenges is how to defend against insider threats in healthcare. Insiders are responsible for more healthcare data breaches than hackers, making the industry unique.

Verizon’s Protected Health Information Data Breach Report highlights the extent of the problem. The report shows 58% of all healthcare data breaches and security incidents are the result of insiders.

Healthcare organizations also struggle to detect insider breaches, with many breaches going undetected for months or even years. One healthcare employee at a Massachusetts hospital was discovered to have been accessing healthcare records without authorization for 14 years before the privacy violations were detected, during which time the records of more than 1,000 patients had been viewed.

Healthcare organizations must not only take steps to reduce the potential for insider breaches, they should also implement technological solutions, policies, and procedures that allow breaches to be detected rapidly when they do occur.

What are Insider Threats?

Before explaining how healthcare organizations can protected against insider threats, it is worthwhile covering the main insider threats in healthcare.

An insider threat is one that comes from within an organization. That means an individual who has authorization to access healthcare resources, which includes EMRs, healthcare networks, email accounts, or documents containing PHI. Resources can be accessed with malicious intent, but oftentimes mistakes are made that can equally result in harm being caused to the organization, its employees, or its patients.

Insider threats are not limited to employees. Any individual who is given access to networks, email accounts, or sensitive information in order to complete certain tasks could deliberately or accidentally take actions that could negatively affect an organization. That includes business associates, subcontractors of business associates, researchers, volunteers, and former employees.

The consequences of insider breaches can be severe. Healthcare organizations can receive heavy fines for breaches of HIPAA Rules and violations of patient privacy, insider breaches can damage an organization’s reputation, cause a loss of patient confidence, and leave organizations open to lawsuits.

According to the CERT Insider Threat Center, insider breaches are twice as costly and damaging as external threats. To make matters worse, 75% of insider threats go unnoticed.

Insider threats in healthcare can be split into two main categories based on the intentions of the insider: Malicious and non-malicious.

Malicious Insider Threats in Healthcare

Malicious insider threats in healthcare are those which involve deliberate attempts to cause harm, either to the organization, employees, patients, or other individuals. These include the theft of protected health information such as social security numbers/personal information for identity theft and fraud, the theft of data to take to new employers, theft of intellectual property, and sabotage.

Research by Verizon indicates 48% of insider breaches are conducted for financial gain, and with healthcare data fetching a high price on the black market, employees can easily be tempted to steal data.

A 2018 Accenture survey conducted on healthcare employees revealed one in five would be prepared to access and sell confidential data if the price was right. 18% of the 912 employees surveyed said they would steal data for between $500 and $1,000.

Alarmingly, the survey revealed that almost a quarter (24%) of surveyed healthcare employees knew of someone who had stolen data or sold their login credentials to an unauthorized outsider.

Disgruntled employees may attempt to sabotage IT systems or steal and hold data in case they are terminated. However, not all acts of sabotage are directed against employers. One notable example comes from Texas, where a healthcare worker used hospital devices to create a botnet that was used to attack a hacking group.

Non-Malicious Insider Threats in Healthcare

The Breach Barometer reports from Protenus/databreaches.net break down monthly data breaches by breach cause, including the number of breaches caused by insiders. All too often, insiders are responsible for more breaches than outsiders.

Snooping on medical records is all too common. When a celebrity is admitted to hospital, employees may be tempted to sneak a look at their medical records, or those of friends, family members, and ex-partners. The motivations of the employees are diverse. The Verizon report suggests 31% of insider breaches were employees accessing records out of curiosity, and a further 10% were because employees simply had access to patient records.

Other non-malicious threats include the accidental loss/disclosure of sensitive information, such as disclosing sensitive patient information to others, sharing login credentials, writing down login credentials, or responding to phishing messages.

The largest healthcare data breach in history – the theft of 78 million healthcare records from Anthem Inc.- is believed to have been made possible because of stolen credentials.

The failure to ensure PHI is emailed to the correct recipient, the misdirection of fax messages, or leaving portable electronic devices containing ePHI unattended causes many breaches each year. The Department of Health and Human Services’ Office for Civil Rights’ breach portal or ‘Wall of Shame’ is littered with incidents involving laptops, portable hard drives, smartphones, and zip drives that have stolen after being left unattended.

How to Defend Against Insider Threats in Healthcare

The standard approach to mitigating insider threats can be broken down into four stages: Educate, Deter, Detect, and Investigate.

Educate: The workforce must be educated on allowable uses and disclosures of PHI, the risk associated with certain behaviors, patient privacy, and data security.

Deter: Policies must be developed to reduce risk and those policies enforced. The repercussions of HIPAA violations and privacy breaches should be clearly explained to employees.

Detect: Healthcare organizations should implement technological solutions that allow them to detect breaches rapidly and access logs should be regularly checked.

Investigate: When potential privacy and security breaches are detected they must be investigated promptly to limit the harm caused. When the cause of the breach is determined, steps should be taken to prevent a recurrence.

Some of the specific steps that can be taken to defend against insider threats in healthcare are detailed below:

Perform Background Checks

It should be standard practice to conduct a background check before any individual is employed. Checks should include contacting previous employers, Google searches, and a check of a potential employee’s social media accounts.

HIPAA training

All healthcare employees should be made aware of their responsibilities under HIPAA. Training should be provided as soon as possible, and ideally before network or PHI access is provided. Employees should be trained on HIPAA Privacy and Security Rules and informed of the consequences of violations, including loss of employment, possible fines, and potential criminal penalties for HIPAA violations.

Implement anti-phishing defenses

Phishing is the number one cause of data breaches. Healthcare employees are targeted as it is far easier to gain access to healthcare data if an employee provides login credentials than attempting to find software vulnerabilities to exploit. Strong anti-phishing defenses will prevent the majority of phishing emails from reaching inboxes. Advanced spam filtering software is now essential.

Security awareness training

Since no technological solution will prevent all phishing emails from reaching inboxes, it is essential – from a security and compliance perspective – to teach employees the necessary skills that will allow them to identify phishing attempts and other email/web-based threats.

Employees cannot be expected to know what actions place data and networks at risk. These must be explained if organizations want to eradicate risky behavior. Security awareness training should also be assessed. Phishing simulation exercises can help to reinforce training and identify areas of weakness that can be tackled with further training.

Encourage employees to report suspicious activity

Employees are often best placed to identify potential threats, such as changes in the behavior of co-workers. Employees should be encouraged to report potentially suspicious behavior and violations of HIPAA Rules.

While Edward Snowden did not work in healthcare, his actions illustrate this well. The NSA breach could have been avoided if his requests for co-workers’ credentials were reported.

Controlling access to sensitive information

The fewer privileges employees have, the easier it is to prevent insider breaches in healthcare. Limiting data access to the minimum necessary amount will limit the harm caused in the event of a breach. You should be implementing the principle of least privilege. Give employees access to the least amount of data as possible. This will limit the data that can be viewed or stolen by employees or hackers that manage to obtain login credentials.

Encrypt PHI on all portable devices

Portable electronic devices can easily be stolen, but the theft of a device need not result in the exposure of PHI. If full disk encryption is used, the theft of the device would not be a reportable incident and patients’ privacy would be protected.

Enforce the use of strong passwords

Employees can be told to use strong passwords or long passphrases, but unless password policies are enforced, there will always be one employee that chooses to ignore those policies and set a weak password. You should ensure that commonly used passwords and weak passwords cannot be set.

Use two-factor authentication

Two-factor authentication requires the use of a password for account access along with a security token. These controls prevent unauthorized access by outsiders, as well as limiting the potential for an employee to use another employee’s credentials.

Terminate access when no longer required

You should have a policy in place that requires logins to be deleted when an employee is terminated, a contract is completed, or employees leave to work for another organization. There have been many data breaches caused by delays in deleting data access rights. Data access should not be possible from the second an employee walks out the door for the last time.

Monitor Employee Activity

If employees require access to sensitive data for work purposes it can be difficult to differentiate between legitimate data access and harmful actions. HIPAA requires PHI access logs to be maintained and regularly checked. Since this is a labor-intensive task, it is often conducted far too infrequently. The easiest way to ensure inappropriate accessing of medical records is detected quickly is to implement action monitoring software and other software tools that can detect anomalies in user activity and suspicious changes in data access patterns.

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House Committee Seeks Advice from Industry Stakeholders on Fixing Cybersecurity Flaws

The continued use of outdated software and the failure to patch vulnerabilities promptly is making cyberattacks on healthcare organizations too easy. This was clearly highlighted by the WannaCry ransomware attacks in May 2017. U.S healthcare providers may have escaped relatively unscathed, but that was not the case across the Atlantic in the UK. The NHS was hit particularly badly by WannaCry. Were it not for the discovery of a kill switch by a security researcher, it could have been a similar story in the U.S.

This week, Symantec published a report on a recently discovered threat group that has been attacking healthcare organizations for three years and accessing highly sensitive information. Lateral movement within a network has been made easy due to the continued use of outdated operating systems.

These are just two examples of several over the past couple of years and the attacks will continue unless action is taken to address the issue.

In the UK, a post-WannaCry assessment by the health industry’s governing body revealed the NHS is still badly prepared for similar attacks. Many vulnerabilities remain unpatched and outdated and unsupported operating systems are still widely used.

Healthcare organizations on both sides of the Atlantic have upgraded some systems but many healthcare providers still rely on legacy software and equipment. All too often there is a lack of visibility into all devices connected to healthcare networks which hampers the remediation of vulnerabilities. Patching all systems promptly remains a major challenge in healthcare.

Action is being taken to address medical device security although progress is slow. Recently, the U.S Food and Drug Administration announced a new plan which will require all medical device manufacturers to incorporate the capability to update their devices throughout the entire life cycle of the products. While such measures will certainly help to keep new medical devices secure, it will do nothing to address the problem with older devices.

The use of legacy software and outdated equipment will continue to leave healthcare organizations vulnerable, but all too often there is little alternative. Aging devices and outdated software continue to be used because there are currently no viable alternatives. Even when it is possible to update devices and operating systems, identifying and managing vulnerabilities is a major challenge, and one that comes at a considerable cost.

Healthcare providers are often forced to conduct a cost-benefit analysis to determine the value of continued use of certain technologies and the cost of remediating vulnerabilities. If the cost of updating and maintaining the devices is too high and there are no viable alternatives that provide the same benefits, the risks associated with the devices have to be accepted.

Even if manufacturers were forced to continue to provide updates to legacy software and equipment, the time and resources that would need to be devoted to cybersecurity would undoubtedly have a negative impact on the ability of manufacturer to develop new devices and more advanced treatments, which would have a negative impact on patients. Unfortunately, there does not appear to be an easy solution.

The U.S. House Energy and Commerce Committee is well aware of the problem and is now seeking help from industry stakeholders on how best to tackle the issue and improve cybersecurity.

“Though hard data about the exact costs are difficult to determine, one cybersecurity professional estimated that fixing a single vulnerability may cost an organization anywhere from $400 to $4,000,” wrote the Committee in its recent Supported Lifetimes Request for Information. “Considering the fact that many popular medical technologies leverage software and hardware with hundreds to thousands of known vulnerabilities, let alone unknown ones, vulnerability identification and management can quickly become a daunting task.”

“To understand the full scope of the challenge and potential paths to address it, we require insight from stakeholders of all sizes, from all parts of the health care sector.”  Input from industry stakeholders and others has been requested by May 31, 2018.

The House Committee on Energy and Commerce Request for Information on Supported Lifetimes can be viewed on this link.

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Report: Healthcare Data Breaches in Q1, 2018

The first three months of 2018 have seen 77 healthcare data breaches reported to the Department of Health and Human Services’ Office for Civil Rights (OCR). Those breaches have impacted more than one million patients and health plan members – Almost twice the number of individuals that were impacted by healthcare data breaches in Q4, 2017.

There was a 10.5% fall in the number of data breaches reported quarter over quarter, but the severity of breaches increased. The mean breach size increased by 130.57% and there was a 15.37% increase in the median breach size.

In Q4, 2017, the mean breach size was 6,048 healthcare records and the median breach size was 1,666 records. In Q1, 2018, the mean breach size was 13,945 records and the median breach size was 1,922 records.

Between January 1 and March 31, 2018, 1,073,766 individuals had their PHI exposed, viewed, or stolen compared to 520,141 individuals in Q4, 2017.

Individuals Impacted by Healthcare Data Breaches in Q1, 2018

Healthcare Records Breached in Q1, 2018

Throughout 2017, healthcare data breaches were occurring at a rate of more than one per day. Compared to 2017, January was a relatively good month for the healthcare industry, with just 22 security incidents reported to the HHS’ Office for Civil Rights.

However, January also saw the largest healthcare data breach of the quarter reported – A hacking incident that potentially resulted in the theft of almost 280,000 records. That incident made January the worst month in terms of the number of healthcare records exposed.

The number of reported data breaches also increased each month, In March, breaches were being reported at the typical rate of one per day.

Q1, 2018 Healthcare Data Breaches

Healthcare Data Breaches in Q1, 2018

Main Causes of Healthcare Data Breaches in Q1, 2018

The healthcare industry is something of an anomaly when it comes to data breaches. In other industries, hacking/IT incidents dominate the breach reports; however, the healthcare industry is unique as insiders cause the most data breaches.

Once again, insiders were behind the majority of breaches. Unauthorized access/disclosure incidents, loss of physical records and devices containing ePHI, and improper disposal incidents accounted for 59.74% of the 77 breaches reported in Q1.

The main cause of breaches in Q1, 2018 was unauthorized access/disclosures – 35 incidents and 45.45% of the total breaches reported in Q1. There were 15 breaches involving the loss or theft of electronic devices containing ePHI, all of which could have been prevented had encryption been used.

Causes of Healthcare Data Breaches, Q1, 2018

Healthcare Records Exposed in Q1, 2018 by Breach Cause

Unauthorized access/disclosure incidents were more numerous than hacking incidents in Q1, although more healthcare records were exposed/stolen in hacking/IT incidents than all other causes of breaches combined.

Healthcare Records Exposed by Breach Cause

Location of Breached PHI in Q1, 2018

Healthcare security teams may be focused on securing the perimeter and preventing hackers from accessing and stealing electronic health information, but it is important not to neglect physical records.  As was the case in Q4, 2017, physical records were the top location of breached PHI in Q1, 2018.

Email, which includes social engineering, phishing attacks and misdirected emails, was the second most common location of breached PHI followed by network servers.

Location of Breached PHI - Q1, 2018

Largest Healthcare Data Breaches of Q1, 2018

In Q1, 2018, there were 18 healthcare security breaches that impacted more than 10,000 individuals. Hacking/IT incidents tend to involve more records than any other breach cause, although in Q1, 2018, there were several large-scale unauthorized access/disclosure incidents, including five of the top ten breaches of the quarter.

The two largest breaches of the year to date affected Oklahoma State University Center for Health Sciences and St. Peter’s Surgery & Endoscopy Center. In both cases a hacker gained access to the network and potentially viewed/obtained patients’ PHI.

The five largest breaches of the quarter accounted for 57% of all records exposed in the quarter. The top 18 data breaches accounted for 87% of all records exposed in the quarter.

Name of Covered Entity Covered Entity Type Individuals Affected Type of Breach
Oklahoma State University Center for Health Sciences Healthcare Provider 279865 Hacking/IT Incident
St. Peter’s Surgery & Endoscopy Center Healthcare Provider 134512 Hacking/IT Incident
Tufts Associated Health Maintenance Organization, Inc. Health Plan 70320 Unauthorized Access/Disclosure
Florida Agency Persons for Disabilities Health Plan 63627 Unauthorized Access/Disclosure
Middletown Medical P.C. Healthcare Provider 63551 Unauthorized Access/Disclosure
Onco360 and CareMed Specialty Pharmacy Healthcare Provider 53173 Hacking/IT Incident
Triple-S Advantage, Inc. Health Plan 36305 Unauthorized Access/Disclosure
ATI Holdings, LLC and its subsidiaries Healthcare Provider 35136 Hacking/IT Incident
City of Houston Medical Plan Health Plan 34637 Theft
Mississippi State Department of Health Healthcare Provider 30799 Unauthorized Access/Disclosure
Agency for Health Care Administration Health Plan 30000 Hacking/IT Incident
Decatur County General Hospital Healthcare Provider 24000 Hacking/IT Incident
Barnes-Jewish Hospital Healthcare Provider 18436 Unauthorized Access/Disclosure
Barnes-Jewish St. Peters Hospital Healthcare Provider 15046 Unauthorized Access/Disclosure
Special Agents Mutual Benefit Association Health Plan 13942 Unauthorized Access/Disclosure
Guardian Pharmacy of Jacksonville Healthcare Provider 11521 Hacking/IT Incident
CarePlus Health Plan Health Plan 11248 Unauthorized Access/Disclosure
Primary Health Care, Inc. Healthcare Provider 10313 Unauthorized Access/Disclosure

Healthcare Data Breaches in Q1, 2018 by Covered Entity

Healthcare providers were the worst affected by healthcare data breaches in Q1, 2018. As was the case in Q4, 2017, 14 health plans experienced a breach of more than 500 records. There were half the number of business associate breaches in Q1, 2018 as there were in Q4, 2017.

Q1, 2018 Healthcare Data Breaches by Entity Type

Healthcare Data Breaches in Q1, 2018 by State

In Q1, healthcare organizations based in 35 states reported breaches of more than 500 records. The worst affected state was California with 11 reported breaches, followed by Massachusetts with 8 security incidents.

There were four security incidents in both Missouri and New York, and three breaches reported by healthcare organizations based in Florida, Illinois, Maryland, Mississippi, Tennessee, and Wisconsin.

Healthcare organizations based in Alabama, Arkansas, Kentucky, Rhode Island, Texas, and Wyoming reported two breaches.

There was one breach experienced in Colorado, Connecticut, District of Columbia, Georgia, Iowa, Maine, Michigan, Minnesota, North Carolina, New Jersey, New Mexico, Nevada, Ohio, Oklahoma, Pennsylvania, Utah, Virginia, Washington and West Virginia.

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Kwampirs Backdoor Used in Targeted Attacks on Healthcare Industry

A relatively recently identified threat group known as Orangeworm is conducting targeted attacks on large healthcare organizations in the United States according to Symantec.

The threat group was first identified in January 2015 and has been conducting supply chain attacks with the aim of installing backdoors on devices used by large healthcare firms. Already, several healthcare providers, IT solution providers, pharmaceutical firms, and medical equipment manufacturers have been attacked.

The Orangeworm threat group has conducted attacks on a wide range of industries, including manufacturing, agriculture, IT, and logistics. Even though these attacks have taken place on companies in seemingly unrelated industries, many targeted companies in these sectors have links to healthcare organizations, such as logistics firms that deliver medical supplies, IT firms that have contracts with healthcare providers, and manufacturers of medical imaging devices. 39% of all confirmed attacks have been on firms operating in the healthcare sector.

Rather than use the spray and pray tactics of ransomware gangs, the Orangeworm attacks appear to be highly targeted. Companies are carefully researched before the attacks take place.

Symantec notes that while attacks have taken place in several countries, the U.S is the most targeted country accounting for 17% of attacks. Large firms operating in the healthcare sector, in particular those with large international operations, appear to be the primary targets.

A common denominator in many of the attacks is the devices on which the backdoor has been installed are used in conjunction with medical imaging devices, such as MRI and X-Ray machines. Several attacks have targeted machines used to help patients complete consent forms for medical procedures.

Once access is gained to a machine and the attackers have determined the device is of value, the Kwampirs backdoor is deployed. Using that device, the threat actors gather information on the device, network shares, mapped drives, and files stored on the infected machine. The Kwampirs backdoor is then aggressively copied onto other machines via network shares. Windows XP machines are most susceptible to this type of attack, which could suggest why machines linked to imaging devices are commonly infected – many of which still run on Windows XP.

Symantec has not discovered any evidence that points to this being a nation-state sponsored attack and suggests this could be the work of an individual or a small group of hackers. It is currently unclear why the attacks are taking place and what the ultimate aim of the attackers is. It is possible that the backdoor is being installed for future attacks on healthcare organizations or to steal patient data, although Symantec suggests the threat group is attacking healthcare firms for corporate espionage purposes.

Fortunately, the attackers do not appear to be overly concerned with being detected. The method used to spread the backdoor laterally is particularly noisy and relatively easy to identify, although some attempts have been made to avoid hash-based detection, such as inserting a random string into the middle of the decrypted payload before it is written to the disk.

Healthcare organizations are being encouraged to analyze their networks and machines for signs of infection using Symantec’s Orangeworm indicators of compromise (PDF).

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Healthcare Compliance Programs Not In Line With Expectations of Regulators

Healthcare compliance officers are prioritizing compliance with HIPAA Privacy and Security Rules, even though the majority of Department of Justice and the HHS Office of Inspector General enforcement actions are not for violations of HIPAA or security breaches, but corrupt arrangements with referral sources and false claims. There are more penalties issued by regulators for these two compliance failures than penalties for HIPAA violations.

HIPAA enforcement by the HHS’ Office for Civil Rights has increased, yet the liabilities to healthcare organizations from corrupt arrangements with referral sources and false claims are far higher. Even so, these aspects of compliance are relatively low down the list of priorities, according to a recent survey of 388 healthcare professionals conducted by SAI Global and Strategic Management Services.

The survey was conducted on compliance officers from healthcare organizations of all sizes, from small physician practices to large integrated hospital systems. The aim of the study was to identify the key issues faced by compliance officers and determine how compliance departments are responding and prioritizing their resources.

When asked to rank their main priorities, dealing with HIPAA data breaches was overwhelmingly the top priority and the biggest concerns were HIPAA privacy and security.

The list of HIPAA enforcement actions has grown considerably over the past two years but there are still fewer penalties than for false claims and arrangements with referral sources. Even so, ensuring claims accuracy was only ranked third in compliance officers’ priority list and arrangement with referral sources was ranked fifth. The survey shows there is a gap between what OIG and DOJ consider to be the highest risk areas and where compliance officers see the greatest risks.

“The question has to be asked as to why, in the face the enforcement agencies’ priorities, compliance officers are placing these high risk-areas in a lower priority,” said former HHS Inspector General and CEO of Strategic Management Services Richard Kusserow. “The takeaway from the survey is that compliance officers should be prepared to better align their priorities and programs with those set out by the regulatory and enforcement agencies.”

Part of the reason for the focus on HIPAA compliance is the increase in enforcement activity by OCR in the past two years, the media activity surrounding healthcare data breaches, and the relatively high fines for covered entities discovered not to have fully complied with HIPAA Rules. With OCR investigating all breaches of more than 500 records, and data breaches now occurring with increasing frequency, it is easy to see why HIPAA compliance is being prioritized.

Even though HIPAA is the main priority for compliance officers and where most resources are focused, only one in five compliance officers feels their organization is well prepared for a HIPAA compliance audit. Last year when the survey was conducted, 30% of compliance officers said they were highly confident that they were well prepared for a HIPAA audit. The percentage of compliance officers who said they are moderately prepared for a HIPAA compliance audit has increased from 50% to 61%, showing the focus on HIPAA compliance is having a positive effect.

The study suggests the workload for compliance officers is increasing, but budgets are stagnant. Compliance officers are increasingly responsible for conducting internal audits and providing legal counsel in addition to overseeing compliance with HIPAA Privacy and Security Rules. The high workload and limited resources mean other aspects of compliance are being neglected. According to the report, “Compliance offices are being stretched thin to meet their obligations.”

While external compliance assessments are highly beneficial, only a quarter of respondents said they use independent third parties to complete those assessments, with three quarters performing self-assessments, internal surveys, and using compliance checklists to evaluate their compliance programs.

“The 2018 Healthcare Compliance Benchmark Survey gives us a better understanding of compliance program development in the healthcare sector and suggests that effectiveness is being measured in terms of output, rather than outcome,” said SAI Global CEO Peter Grana. “It is abundantly clear that there is a need for healthcare organizations to remove barriers and increased responsibilities being laid on their compliance offices that distract from the development of effective risk controls.”

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