Windows 7 End-of-Life (EOL): How to Maintain HIPAA Compliance

You may soon be facing a HIPAA compliance headache on the workstations in your healthcare facility. Microsoft support for Windows 7 and Windows Server 2008 ends on January 14, 2020. 

No more security patches will be issued after that date. This puts those operating systems at odds with the HIPAA administrative safeguards, which include the specification for “protection from malicious software,” specifically “procedures for guarding against, detecting, and reporting malicious software.”

The end of support means that workstations running those operating systems will be unpatched against new exploits, leaving them highly vulnerable, and therefore, out of HIPAA compliance.

If you are still running those older operating systems, you’re not alone. Many companies still have Windows 2008 servers and Windows 7 workstations in their environments. While these operating systems are ten years old and newer systems are certainly better, organizations keep using them. They are very stable and continue to do their jobs well. But the longer you hang onto them, the greater the risk to your organization.

First, let’s talk about the risks, and then how to alleviate them without having to purchase all-new systems at once.

Lessons from Past Compliance Audits

After a data breach occurs, history shows that regulators conduct a thorough audit of the affected organization’s entire environment. They look at everything. Although the breach was caused by an employee walking out with a thumb drive that was lost or stolen, every other instance of non-compliance that the auditors uncover is subject to a fine, even if it had nothing to do with the breach. Organizations that have been found using Windows products that were past their end-of-life — such as Windows XP — have been fined for that in the past. Undoubtedly, Windows 7 and Server 2008 will be no exception.

Considering the Alternatives

Under the language of the HIPAA rule, specifications are listed as either required or addressable. “Protection from malicious software” is an addressable specification. That gives organizations a bit of wiggle room. Complying with an addressable specification involves evaluating the risk, considering the measures to mitigate it, coming up with a reasonable alternative that is equivalent, and documenting it. (That’s the short version; here’s the official source on how to meet an addressable specification.)

Let’s say you find it impossible or at least extremely cost-prohibitive to replace all of your out-of-compliance operating systems by January 14. You could address the HIPAA specification by updating a set number of systems every month between now and the end of 2020, until all have been updated. In the meantime, you implement an Endpoint Detection and Response (EDR) monitoring system to keep an eye on the unpatchable systems, as well as use encryption on the systems that hold personal health information (PHI).

Hopefully, you have already performed this sort of analysis across all of the HIPAA specifications as part of your overall compliance effort. HIPAA requires you to perform a risk analysis, have a risk management plan, and document them both. Those are the first documents an examiner will want to see.

At FIT Solutions, we can advise you on all of the aspects of IT that impact your ability to comply with HIPAA. That includes helping you with your risk management and risk assessment plans and documentation, as well as assisting with your Windows 7 and Windows Server 2008 end-of-life planning.

Call us today at 888-339-5694.

Business Continuity for Senior Care: How an SD-WAN Protects Your Patients

Your nursing home or skilled nursing facility likely relies heavily on your Internet connection for delivering patient care.

If your electronic health record (EHR) or electronic medical record (EMR) system is hosted in the cloud, staff access to patient treatment plans, physician orders, medication dosages and other critical information depends on a reliable Internet link. Plus, if you rely on voice-over-IP for your telephone systems, that’s another system that is absolutely critical for patient care. It’s needed for making 911 calls, timely communication with physicians, receiving urgently needed lab results, and the many, many other types of medical information that are routinely handled by phone. What happens if your primary Internet connection fails?

Regulatory Considerations

Regulators are keenly aware of the importance of communication. That’s why Internet uptime is woven into the fabric of healthcare regulations that deal with business continuity and disaster recovery, specific to senior care, at the state and federal levels.

Addressing those requirements is vital for protecting your patients and your organization. Fortunately, there’s a relatively new technology that’s ideal for managing redundant Internet links and providing intelligent failover. SD-WAN stands for Software-Defined Wide Area Network. It’s a mouthful that boils down to a simple idea: using software instructions to intelligently choose between multiple wide area network connections (that is, multiple Internet connections) when sending or receiving data traffic.

Out with the Old — In with the New

Here’s why an SD-WAN is better than the old approach to providing redundant failover. The old method for a backup Internet connection was to maintain one connection as the primary and designate another as secondary. This was an all-or-nothing proposition: The secondary sat idle until needed. The setup required regular testing to verify the secondary was still functional.

An SD-WAN allows both connections to serve as the primary. The software intelligently chooses between the two connections based on various factors, such as the type of traffic (voice or different types of data) and the capability and quality of the connection (available bandwidth, latency and similar parameters). Two or more connections can be actively used, and when one link goes down, the traffic passes to the other automatically and immediately. Here’s how well it works: If you initiate a voice-over-IP call, and then unplug the connection, the SD-WAN switches to the other connection with little or no hint of an interruption in the conversation.

Rather than the secondary connection sitting idle, it can be put to use and effectively increase the available bandwidth. The pooled bandwidth and redundancy make it possible to choose less expensive connections, such as combining a cable and DSL connection rather than more-expensive fiber circuits. If you procure the two connections from different providers, then you’re protected if either provider experiences an outage. The SD-WAN will ensure that access to critical systems will remain.

Modern SD-WAN implementations can be configured without entering traditional network parameters such as IP addresses or port numbers. This makes an SD-WAN especially attractive to organizations that have multiple sites, as is often the case in senior care. SD-WAN technology masks the complexities of maintaining redundant connections and switching them across multiple sites. It just works, which is what we all want from our technology.

At FIT Solutions, we work as advisors to our senior-care clients on multiple aspects of IT. Assistance with the technology aspects of your backup, disaster recovery and emergency preparedness plans is a key part of the offering. We know the legal and regulatory requirements you face, and can provide recommendations on administrative practices, technological implementation and support, or active management of your systems. We can help you determine whether SD-WAN technology — and which of the available options — is right for you. Call us today at 888-339-5694.

Public Wi-Fi Security for Senior Care: 4 Tips for Keeping Patient Data Safe

As the baby boom generation enters the Senior Care market, skilled nursing, assisted living and other facilities that serve to the senior population face a new challenge.

They have to meet the technology-access expectations of tech-savvy patients and their families. Wi-Fi access is now an essential part of the service mix for residents and visitors.

Since these are healthcare facilities, though, HIPAA compliance and patient-safety issues are even more paramount. Roaming caregivers require their own Wi-Fi access to electronic health record (EHR) or electronic medical record (EMR) systems. Monitoring, alerting and other systems that directly support care delivery might also connect via Wi-Fi. Unsecured guest and resident devices connecting to the same network as medically critical devices present a huge risk.

Here are four tips for safely making Wi-Fi available for senior patients and residents, visitors and guests while preventing compromises and addressing the compliance issues.

1.  Use business-class Wi-Fi technology to segregate the networks. Business-class technology allows you to use separate Wi-Fi SSIDs to isolate networks. At minimum, create one for resident/guess access and one for caregivers/staff. Put the guest network in a DMZ or otherwise isolate its internet access and block access to the staff network. (Business-class technology is a must in a senior-care facility for reasons other than security. It generally delivers more-robust coverage than consumer-grade devices, including support for multiple access points.)

2.  Enforce policies to keep the staff passphrase secure. Staff might be tempted to share their password with guests and residents, especially if the resident Wi-Fi enforces bandwidth throttling that limits data consumption. Discourage passkey-sharing by requiring a longer and more-complex passphrase for the staff network, while making the guest passkey shorter and easier to remember and enter. The best practice is to enact a written policy that prohibits sharing the staff passkey with residents or guests, or connecting their devices to the staff network.

3.  Hide the Wi-Fi SSID for the staff network. By not broadcasting the SSID, it won’t show as a connection option. Moreover, if you don’t share the SSID with the staff, they won’t be able to connect any device on their own. This means IT personnel may need to occasionally help with getting equipment connected, but this is often easier than having to change the passkeys on all the devices later because residents are found to be connecting to the staff network.

4.  Add an extra layer of sign-on security. Consider one or both of these options. MAC address filtering allows pre-authorized devices — and only those devices — to connect to the staff network. It can be difficult to administer, however. A much more effective and seamless approach is to use a single sign-on solution (such as Okta or Onelogin) that allows access only when a user enters their staff email address and password.

Of course, there’s more to compliance with HIPAA, HITECH and other regulations than just securing Wi-Fi access, but the tips above deal effectively with one of the biggest vulnerabilities that senior care facilities face.

If you would like to know more about security in a senior care setting, we’re here to help. You can learn more about FIT Solutions managed IT services for healthcare by calling us at (888) 339-5694.

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