September 09, 2015, Andrew Hicks, Managing Principal, Coalfire
It looked like the 8th annual conference may have garnered record-breaking attendance as I noticed hotel staff rushing to add skirted tables and chairs to the back of the room to accommodate a standing-room-only crowd. I guess that was to be expected given the star-studded line-up of presenters including HHS OCR Director Jocelyn Samuels, her brand new Deputy Director, Deven McGraw, and the OCR enforcer, Iliana Peters. We also heard from government officials at the FTC, the ONC, NIST’s NCCoE, and the HHS Preparedness and Response office. The audience responded to each session with a line of people trailing from the microphone set up for Q&A – and with excellent questions, too!
One gentleman posed a question (or actually, a problem) to Director Samuels about how small healthcare organizations simply aren’t securing data and getting compliant. With her usual positive and ‘hopeful’ words (a word she said that the government is famous for using) she pointed out the many tools and endless information available on the OCR’s web site. She added that they are planning to redesign and launch their new web site ‘soon’ – apparently another commonly-used term by the government. Immediately the gentleman stopped her and said that the problem is not that these healthcare organizations are not aware of what they need to do and what’s out there to help them get it done…it’s simply that they aren’t doing it. He added that announcements of new fines and penalties resulting from OCR investigations are not helping. The room broke out into applause for the gentleman’s response as we all shared the pain of not having a mandate in the industry to force these organizations to comply.
This brings me to a panel discussion about best practices for safeguarding the confidentiality, integrity and availability of ePHI where the audience could pose all sorts of questions about executing a risk analysis, incident response planning, BYOD issues, access controls, encryption, and the security of medical devices and the cloud – the same old issues we talk about over and over. But one question for the panel was about the recent HITRUST CSF certification mandate that several large covered entities have placed on more than 7,500 business associates, to be completed in the coming months. What did the panel think of this gutsy move? They all thought it was a good idea then they moved on to the next question.
But it’s more than a good idea – whether the industry is going to mandate compliance with the HITRUST Common Security Framework or another risk management framework, organizations just need to pick one and get busy with a program to secure data. To be clear, a compliance framework outlines the regulatory compliance standards relevant to the organization and the business processes and internal controls the organization has in place to adhere to these standards. So sure the OCR random audits will begin ‘soon’ (probably 2016) and sure, both covered entities and business associates could be caught unprepared…so why wait for a mandate and instead just do the right thing…it’s just good business sense. I’m ‘hopeful’ that healthcare organizations will get the message and get busy!
Andrew Hicks — Managing Principal, Coalfire
Coalfire started in 2001 with a simple idea – cyber threats are increasing, compliance mandates are getting more complicated, and a well-designed cybersecurity program can help fuel your overall success.
Coalfire helps organizations comply with global financial, government, industry and healthcare mandates while helping build the IT infrastructure and security systems that will protect their business from security breaches and data theft. The company is a leading provider of IT advisory services for security in retail, payments, healthcare, financial services, higher education, hospitality, government and utilities.
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Created in honor of the late co-founder of Coalfire, the Richard E. Dakin Fund at The Denver Foundation is supporting scholarship programs at several universities for promising college students studying cybersecurity and related fields.
Security is a team game. If your organization values both independence and security, perhaps we should become partners.
The increased need for cyber security has become a common enterprise priority across the globe. However, industry requirements for effective cyber risk management are as distinct as the individual entities under fire. Enterprises and government organizations need more than an off-the-shelf audit to provide an effective threat assessment. They need industry- and organization-specific insights, tools and processes to protect digital assets and ensure compliance.
Coalfire can help cloud service providers prioritize the cyber risks to the company, and find the right cyber risk management and compliance efforts that keeps customer data secure, and helps differentiate products.
“Success” at a government entity looks different than at a commercial organization. Create cybersecurity solutions to support your mission goals with a team that understands your unique requirements.
The financial services industry was built upon security and privacy. As cyber-attacks become more sophisticated, a strong vault and a guard at the door won’t offer any protection against phishing, DDoS attacks and IT infrastructure breaches.
The continuum of care is a concept involving an integrated system of care that guides and tracks patients over time through a comprehensive array of health services spanning all levels of care. Interoperability is the central idea to this care continuum making it possible to have the right information at the right time for the right people to make the right decisions.
Maintaining network and data security in any large organization is a major challenge for information systems departments. However, in the higher education environment, the protection of IT assets and sensitive information must be balanced with the need for ‘openness’ and academic freedom; making this a more difficult and complex task.
When it comes to cyber threats, the hospitality industry is not a friendly place. Hotels and resorts have proven to be a favorite target for cyber criminals who are looking for high transaction volume, large databases and low barriers to entry.
The payments industry is undergoing rapid changes and unfortunately, an increasing risk for data breaches. Cyber criminals are growing increasingly businesslike, and payments leaders need to move quickly to cover their cyber risk.
The food and beverage industry is under attack from cyber criminals intent on stealing payment information. The food and beverage industry makes up the highest percentage of breach investigations, at nearly 73 percent, according to Visa.
The global retail industry has become the top target for cyber terrorists, and the impact of this onslaught has been staggering to merchants. To secure the complex IT infrastructure of a retail environment, merchants must embrace enterprise-wide cyber risk management practices that reduces risk, minimizes costs and provides security to their customers and their bottom line.
Private enterprises serving government and state agencies need to be upheld to the same information management practices and standards as the organizations they serve. Coalfire has over 16 years of experience helping companies navigate increasing complex governance and risk standards for public institutions and their IT vendors.
Technology innovations are enabling new methods for corporations and governments to operate and driving changes in consumer behavior. The companies delivering these technology products are facilitating business transformation that provides new operating models, increased efficiency and engagement with consumers as businesses seek a competitive advantage.
Cybersecurity has entered the list of the top five concerns for U.S. electric utilities, and with good reason. According to the Department of Homeland Security, attacks on the utilities industry are rising "at an alarming rate."
Cyber risk management, advisory, technology and compliance services. Manage risk and maximize return on investment to prevent data breaches and theft. Coalfire’s solutions are led by a team of industry experts that help enterprise organizations understand a wide range of compliance and risk management initiatives, which enables a consistent cybersecurity framework across the organization.
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