After a brief decline in healthcare breaches, 2023 saw a 45% increase in reported breaches of 500 or more healthcare records. * In an era where a single cybersecurity breach can compromise thousands of sensitive patient records, the imperative for robust digital defenses for PHI protection in behavioral health has never been more critical.
This responsibility extends beyond meeting compliance standards. It is a fundamental aspect of an ethical commitment to client confidentiality and the integrity of organizational services. In response to the challenges faced by smaller agencies, we’ve tailored a practical, two-tiered cybersecurity strategy focused on practices consistent with HIPAA and NIST 800-171 requirements. This strategy starts with foundational security practices and then adds important protections to ensure a seamless fusion of patient care and data confidentiality.
Foundational Practices
- Robust Access Control: Implement strong access controls, augmented with multifactor authentication, to significantly lower the risk of unauthorized PHI access. Microsoft asserts that MFA can block over 99.9 percent of account compromise attacks.
- HIPAA Rules: §164.312(a)(1)
- NIST 800-171 Controls: 3.5.3
- Comprehensive Staff Training: Regular training sessions on cybersecurity best practices, especially in identifying phishing attempts, are crucial to reducing human error. Cybersecurity leader Cloudflare estimates that 90% of successful cyber attacks start with email phishing, which continues to be very lucrative for attackers.
- HIPAA Rules: §164.308(a)(5)
- NIST 800-171 Controls: 3.2.1, 3.2.2
- Encryption: Encrypt PHI when stored and transmitted to ensure data remains secure even if improperly accessed. HIPAA Journal notes that the HIPAA encryption requirements only occupy a small section of the Technical Safeguards in the Security Rule (45 CFR §164.312), yet they are some of the most significant requirements in terms of maintaining the confidentiality of electronic Protected Health Information (ePHI) and for determining whether a data breach is a notifiable incident under the Breach Notification Rule.
- HIPAA Rules: §164.312(a)(2)(iv)
- NIST 800-171 Controls: 3.13.16
- System Updates and Data Backups: Keep systems updated to protect against vulnerabilities and regularly back up data to ensure quick recovery in case of incidents. Ben McLaughlin, VP of Lyve Cloud at Seagate Technology says “A rise in ransomware as a service and extortion tactics means that organizations need to be more vigilant than ever and ensure their data is backed up and protected.”
- HIPAA Rules: §164.308(a)(7), §164.308(a)(5)(ii)(B)
- NIST 800-171 Controls: 3.14.2, 3.6.2
- Incident Response Plan: Prepare for potential threats with a plan that covers threat containment, eradication, and efficient recovery using your backups. HealthTech.net says “Given the challenges that organizations face in keeping cyberattackers at bay, an effective incident response plan is essential. Having a plan in place helps to ensure that the response is swift and organized and that an organization is able to avoid rash decisions that could exacerbate the situation.”
- HIPAA Rules: §164.308(a)(6)(ii)
- NIST 800-171 Controls: 3.6.1
Next Steps
- Risk Assessment: Regularly evaluate potential vulnerabilities within your agency to prioritize and tailor your cybersecurity efforts.
- HIPAA Rules: §164.308(a)(1)(ii)(A)
- NIST 800-171 Controls: 3.11.1
- Firewalls: Use firewalls to safeguard your internal network from external threats and control data traffic.
- HIPAA Rules: §164.312(e)(1)
- NIST 800-171 Controls: 3.13.1
- Monitoring Logins: Track login attempts to identify and respond to potential security breaches quickly.
- HIPAA Rules: §164.308(a)(1)(ii)(D)
- NIST 800-171 Controls: 3.1.1
- Anti-Malware Software: Deploy comprehensive anti-malware solutions to protect against malicious software.
- HIPAA Rules: §164.308(a)(5)(ii)(B)
- NIST 800-171 Controls: 3.14.1
- Secure Wi-Fi Networks: Ensure your Wi-Fi networks are secure, with strong encryption and hidden SSIDs to prevent unauthorized access.
- HIPAA Rules: §164.312(e)(1)
- NIST 800-171 Controls: 3.13.1
- Data Minimization: Limit the collection and retention of PHI to only what is necessary, reducing potential breach impacts.
- HIPAA Rules: §164.502(b), §164.514(d)
- NIST 800-171 Controls: 3.1.4, 3.4.1
- Vendor Management: Ensure that any vendors with access to PHI also adhere to stringent cybersecurity practices.
- HIPAA Rules: §164.308(b)(1), §164.502(e), §164.504(e)
- NIST 800-171 Controls: 3.12.1, 3.13.11
Behavioral health agencies can build a robust cybersecurity framework by implementing these essential steps. This comprehensive approach is key to protecting sensitive client data and maintaining the high trust and care standards intrinsic to behavioral healthcare.
Xpio Health is committed to delivering cybersecurity solutions specifically aligned with behavioral health organizations’ intricacies. Our approach goes beyond standard protocols, integrating in-depth knowledge of HIPAA, NIST, and HITRUST frameworks to craft strategies that address your unique challenges.
Do you feel fully confident in your agency’s cybersecurity posture? If there’s even a hint of doubt, it’s a risk you can’t afford. Let us help you assess and strengthen your defenses. Contact Xpio Health today.