RSI Security

Maintain HIPAA Compliant Cloud Storage in 2023

computer

Healthcare providers are some of the main beneficiaries of IT advancements, and the advantages of cloud technologies are no exception. Cloud storage facilitates rapid access to patient data in healthcare settings to help guide medical evaluations and treatment decisions. However, the Health Insurance Portability and Accountability Act of 1996 strictly regulates the use and disclosure of protected health information (PHI), and cloud storage can potentially compromise compliance. So, how do you maintain HIPAA-compliant cloud storage?

 

HIPAA-Compliant Cloud Storage

When PHI is stored electronically (ePHI), cybersecurity measures must be implemented for HIPAA compliance that may seem opposed to the access benefits achieved with cloud storage. However, healthcare entities and organizations that must maintain compliance can still leverage cloud access if done so properly.

Implementing HIPAA-compliant cloud storage depends on an understanding of:

Developing and maintaining HIPAA-compliant cloud computing architecture and storage access policies presents healthcare IT security teams with significant challenges. Partnering with a cybersecurity and compliance expert can help simplify cloud usage that adheres to regulations.


Download Our Complete Guide to Navigating Healthcare Compliance Whitepaper


PHI and ePHI

Protected health information (PHI) and its digital counterpart (ePHI) comprise individuals’ personal data utilized within healthcare settings. HIPAA covers 18 categories—termed “identifiers”—of personally identifiable information (PII) that are regarded as PHI:

  1. Names
  2. Residence location (or specific geographic information)
  3. Important dates (e.g., date of birth, treatment dates)
  4. Telephone numbers
  5. Fax numbers
  6. Email addresses
  7. Social Security number (SSN)
  8. Medical record numbers or identifiers
  9. Health plan beneficiary numbers or identifiers
  10. Account numbers (e.g., credit card data)
  11. ID or license numbers
  12. Vehicle identifiers (e.g., license plates, vehicle identification number (VIN))
  13. Device identifiers and serial numbers
  14. Website URLs
  15. IP addresses
  16. Biometric data (e.g., fingerprints)
  17. Full-face photographic (or comparable) imagery
  18. Other unique numbers, characteristics, or codes that may be used to identify the individual

Any data that may be categorized according to these 18 identifiers and is stored in the cloud must be interacted with via HIPAA-compliant processes.

 

Request a Free Consultation

 

Broader HHS Definition of PHI

More broadly, HHS defines PHI as any data that may identify an individual—including demographic data and regardless of any temporal relation to the individual or provided healthcare. This definition covers:

 

Who is Subject to HIPAA Compliance?

HIPAA regulations and guidance utilize specific terminology when referring to the various organizations subject to compliance:

HIPAA regulations pertaining to cloud storage implementations mostly affect covered entities and IT or cybersecurity service providers. However, any organization that stores PHI in a cloud environment or interacts with it via cloud computing must follow the same regulatory adherence.

 

HIPAA Regulations

HIPAA constitutes one of the more stringent and broadly applicable compliance standards and spans numerous “rule” publications issued by the US Department of Health and Human Services (HHS). HIPAA enforcement falls under HHS’ Office for Civil Rights (OCR).

By regulating the use and disclosure of patients’ PHI, HIPAA affects virtually all aspects of healthcare.

Note that, unlike many other compliance frameworks, HIPAA does not stipulate specific cybersecurity or other IT implementations. Instead, HIPAA focuses on the results (i.e., proper, confidential use and disclosures).

 

HIPAA Rules Relevant to Cloud Storage

The HIPAA regulations relevant to cloud storage are:

 

Cloud Storage and HIPAA Compliance

As HIPAA doesn’t stipulate specific technology implementations, adopting cloud storage doesn’t inherently create compliance violations. Cloud usage remains compliant if processes and user access adhere to the permitted, confidential uses and disclosures governing PHI protections.

According to the Security Rule, HIPAA-compliant storage must enforce:

So long as cloud access and use adhere to these restrictions, your organization will maintain HIPAA-compliant file storage.

 

Business Associate Agreements (BAA) and Cloud Storage

If a covered entity (or business associate) hosts ePHI in a fully secured private cloud environment, their standard HIPAA adherence efforts may be sufficient for compliant cloud storage.

However, if a covered entity partners with a cloud services provider to remotely host ePHI on off-site servers, both parties must create and sign a Business Associate Agreement (BAA). A BAA is a contractual agreement that stipulates the appropriate technical, administrative, and security safeguards enacted to protect ePHI, extending to state the limited, permissible uses and disclosures of the data.

Should a business associate suffer a data breach (as defined by HIPAA), they must notify their covered entity partner within 60 days.

 

HIPAA and the HITRUST CSF

The HITRUST Common Security Framework (CSF) was initially established to simplify HIPAA compliance. Though the CSF has been expanded to include numerous other frameworks via comprehensive mapping, its implementation will significantly help ensure HIPAA compliance—including HIPAA-compliant cloud storage.

RSI Security is a HITRUST expert and can facilitate your organization’s implementation and certification assessment.

 

Implementing HIPAA-Compliant Cloud Storage

HIPAA compliance quickly becomes a nebulous challenge for covered entities and their business associates. Since HIPAA does not outline explicit technical specifications to allow for organization diversity and scaling, the process of determining the appropriate solutions to implement and services to use is left to entities themselves. As a result, many organizations have turned to the HITRUST CSF for explicit technical guidance.

As a HIPAA and HITRUST compliance expert and cybersecurity services provider, partnering with RSI Security will help ensure your organization’s regulatory adherence.

To get started on implementing HIPAA-compliant cloud storage or other compliance efforts, contact RSI Security today.

 

 

Exit mobile version