Remote Access & HIPPA



  • @JasGot said in Remote Access & HIPPA:

    HIPAA doesn't require encryption.

    However, if your chosen encryption method meets the FIPS 140-2 standards, HIPAA will provide a safe harbor for you in the event of a data breach.

    The problem is that FIPS 140-2 compliance is time consuming and not cost effective for most remote access developers/providers.

    It's very important to note that FIPS 140-2 compliant is not the same as FIPS 140-2 certified. In order to be certified, it must go through a painful ATO process which can take over a year.

    With all that being said, HIPAA is extremely lenient, too lenient. Basically as long as you are using some sort of common sense, you'll meet HIPAA



  • @IRJ said in Remote Access & HIPPA:

    With all that being said, HIPAA is extremely lenient, too lenient. Basically as long as you are using some sort of common sense, you'll meet HIPAA

    And there is a really good chance that if you don't use common sense, you'll still meet HIPAA 😞



  • @scottalanmiller said in Remote Access & HIPPA:

    @IRJ said in Remote Access & HIPPA:

    With all that being said, HIPAA is extremely lenient, too lenient. Basically as long as you are using some sort of common sense, you'll meet HIPAA

    And there is a really good chance that if you don't use common sense, you'll still meet HIPAA 😞

    Like using faxes...



  • @Dashrender said in Remote Access & HIPPA:

    @scottalanmiller said in Remote Access & HIPPA:

    @IRJ said in Remote Access & HIPPA:

    With all that being said, HIPAA is extremely lenient, too lenient. Basically as long as you are using some sort of common sense, you'll meet HIPAA

    And there is a really good chance that if you don't use common sense, you'll still meet HIPAA 😞

    Like using faxes...

    Now that said - Medicaid/Medicare programs are currently tied to Merit-based Incentive Payment System (MIPS)/meaningful use incentive programs.

    In the beginning, these programs paid providers directly for "going above and beyond" with features that where claimed to improve patient care. This was meant to entice providers to adobt EHRs and other programs, policies, reportings that would otherwise likely never be implemented. Of course, they started out as totally voluntary with a reward but at the same time providers were told there would come a time when they would be come required, and if not fulfilled, the providers willing to Medicaid/Medicare would be penalized.
    Well that penalty time is either here or nearly here.

    All that was to help you understand that the new Merit-based Incentive Payment System (MIPS)/meaningful use programs now have a measure on what percent of doctor to doctor communication is going through Direct Messaging vs faxing. If the faxing is to high, the providers will be penalized... so they are finally working to move past faxes.

    Sadly, the system is still to broken - as Direct Messaging is not meant for anything more than Provider to Provider communication. This leaves out many non-Providers who still need this information, like the patient, lawyers, insurance companies, etc. Now insurance companies already get the information via a different secure method, but patients and lawyers don't... and if you send to them, they count against you in the faxing scheme.



  • @IRJ said in Remote Access & HIPPA:

    It's very important to note that FIPS 140-2 compliant is not the same as FIPS 140-2 certified

    Yes! And thank you for spotting that. It's the Certification that is a total PITA.



  • @Dashrender said in Remote Access & HIPPA:

    @Dashrender said in Remote Access & HIPPA:

    @scottalanmiller said in Remote Access & HIPPA:

    @IRJ said in Remote Access & HIPPA:

    With all that being said, HIPAA is extremely lenient, too lenient. Basically as long as you are using some sort of common sense, you'll meet HIPAA

    And there is a really good chance that if you don't use common sense, you'll still meet HIPAA 😞

    Like using faxes...

    Now that said - Medicaid/Medicare programs are currently tied to Merit-based Incentive Payment System (MIPS)/meaningful use incentive programs.

    In the beginning, these programs paid providers directly for "going above and beyond" with features that where claimed to improve patient care. This was meant to entice providers to adobt EHRs and other programs, policies, reportings that would otherwise likely never be implemented. Of course, they started out as totally voluntary with a reward but at the same time providers were told there would come a time when they would be come required, and if not fulfilled, the providers willing to Medicaid/Medicare would be penalized.
    Well that penalty time is either here or nearly here.

    All that was to help you understand that the new Merit-based Incentive Payment System (MIPS)/meaningful use programs now have a measure on what percent of doctor to doctor communication is going through Direct Messaging vs faxing. If the faxing is to high, the providers will be penalized... so they are finally working to move past faxes.

    Sadly, the system is still to broken - as Direct Messaging is not meant for anything more than Provider to Provider communication. This leaves out many non-Providers who still need this information, like the patient, lawyers, insurance companies, etc. Now insurance companies already get the information via a different secure method, but patients and lawyers don't... and if you send to them, they count against you in the faxing scheme.

    Ohio Medicare and Medicade providers still have to use an Internet Explorer plugin to access the state system. It's nothing but scary to anyone that knows anything about security.



  • @travisdh1 said in Remote Access & HIPPA:

    @Dashrender said in Remote Access & HIPPA:

    @Dashrender said in Remote Access & HIPPA:

    @scottalanmiller said in Remote Access & HIPPA:

    @IRJ said in Remote Access & HIPPA:

    With all that being said, HIPAA is extremely lenient, too lenient. Basically as long as you are using some sort of common sense, you'll meet HIPAA

    And there is a really good chance that if you don't use common sense, you'll still meet HIPAA 😞

    Like using faxes...

    Now that said - Medicaid/Medicare programs are currently tied to Merit-based Incentive Payment System (MIPS)/meaningful use incentive programs.

    In the beginning, these programs paid providers directly for "going above and beyond" with features that where claimed to improve patient care. This was meant to entice providers to adobt EHRs and other programs, policies, reportings that would otherwise likely never be implemented. Of course, they started out as totally voluntary with a reward but at the same time providers were told there would come a time when they would be come required, and if not fulfilled, the providers willing to Medicaid/Medicare would be penalized.
    Well that penalty time is either here or nearly here.

    All that was to help you understand that the new Merit-based Incentive Payment System (MIPS)/meaningful use programs now have a measure on what percent of doctor to doctor communication is going through Direct Messaging vs faxing. If the faxing is to high, the providers will be penalized... so they are finally working to move past faxes.

    Sadly, the system is still to broken - as Direct Messaging is not meant for anything more than Provider to Provider communication. This leaves out many non-Providers who still need this information, like the patient, lawyers, insurance companies, etc. Now insurance companies already get the information via a different secure method, but patients and lawyers don't... and if you send to them, they count against you in the faxing scheme.

    Ohio Medicare and Medicade providers still have to use an Internet Explorer plugin to access the state system. It's nothing but scary to anyone that knows anything about security.

    oh yeah, don't get me started.... the gov't passes laws, but doesn't have to follow them.



  • @Dashrender said in Remote Access & HIPPA:

    oh yeah, don't get me started.... the gov't passes laws, but doesn't have to follow them.

    Well they pass laws says that the law doesn't apply to them.

    Actually the law seems pretty clear... you can't use their system.



  • I would be more worried about a vulnerability in the javascript framework supporting MeshCentral, so i would NOT put the MeshCentral server on the internet directly, but inside VPNs. Each of the sites on one VPN and the HIPAA site on another standalone VPN. MeshCentral inside both VPNs.

    I would second what @JaredBusch said about the HIPAA site and automatic control of the desktop. I would hope if you need control after hours, you could simply reboot the machine and then no consent is necessary.

    Lastly, there is a spot in the meshCentral configuration file and a cli option that logs anyone in without authentication - "User". It was meant for testing, enable "User" and all authentication is bypassed and logons occur automatically. One just might think keepass autologon was working really fast. So delete the User option from /opt/meshcentral/meshcentral-data/config.json and never pass it on the cli. Ditto for the "nousers" option.



  • @rjt said in Remote Access & HIPPA:

    I would be more worried about a vulnerability in the javascript framework supporting MeshCentral, so i would NOT put the MeshCentral server on the internet directly, but inside VPNs. Each of the sites on one VPN and the HIPAA site on another standalone VPN. MeshCentral inside both VPNs.

    And limit it to MC traffic, not open traffic between sites.



  • @rjt said in Remote Access & HIPPA:

    I would hope if you need control after hours, you could simply reboot the machine and then no consent is necessary.

    If you have an admin account, you should be good without rebooting anyway.



  • @rjt said in Remote Access & HIPPA:

    I would second what @JaredBusch said about the HIPAA site and automatic control of the desktop. I would hope if you need control after hours, you could simply reboot the machine and then no consent is necessary.

    You either have consent on or off, you don't flip flop without having what seems like a clear workaround to what is supposed to be a security benefit.



  • @scottalanmiller said in Remote Access & HIPPA:

    @rjt said in Remote Access & HIPPA:

    I would be more worried about a vulnerability in the javascript framework supporting MeshCentral, so i would NOT put the MeshCentral server on the internet directly, but inside VPNs. Each of the sites on one VPN and the HIPAA site on another standalone VPN. MeshCentral inside both VPNs.

    And limit it to MC traffic, not open traffic between sites.

    Don't encourage stupid. What would be the point of this? What is the gain?

    MeshCenctral (MC), and ScreenConnect, encrypt all communication between the agent on the client and the tech connection. This is done before/outside of web traffic SSL, always has been.

    The web traffic to the MC server can or can not be SSL, that is a separate piece.



  • @Dashrender said in Remote Access & HIPPA:

    @rjt said in Remote Access & HIPPA:

    I would second what @JaredBusch said about the HIPAA site and automatic control of the desktop. I would hope if you need control after hours, you could simply reboot the machine and then no consent is necessary.

    You either have consent on or off, you don't flip flop without having what seems like a clear workaround to what is supposed to be a security benefit.

    I have not, yet, looked back at the MC consent setup once it was implemented. Assuming it was done correctly, consent is permission based, so you could have an account that does not require consent. But you would need auditing on any use of the account.



  • @JaredBusch said in Remote Access & HIPPA:

    @Dashrender said in Remote Access & HIPPA:

    @rjt said in Remote Access & HIPPA:

    I would second what @JaredBusch said about the HIPAA site and automatic control of the desktop. I would hope if you need control after hours, you could simply reboot the machine and then no consent is necessary.

    You either have consent on or off, you don't flip flop without having what seems like a clear workaround to what is supposed to be a security benefit.

    I have not, yet, looked back at the MC consent setup once it was implemented. Assuming it was done correctly, consent is permission based, so you could have an account that does not require consent. But you would need auditing on any use of the account.

    I was pretty much assuming the use of two accounts - or (more crazily) log in with admin - change the permission, etc... but again, that would be crazy.

    But the ability to do that more or less defeats the purpose... because you can choose to be a bad guy and just change that setting as you want and see what you want.... yeah logs are supposed to show what you're doing - but still.

    But you have clients who have you in that spot, do you have a during hours and after hours account you use to support them?


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