HIPAA Best Practices and Priorities for 2024

Introduction: 

HIPAA-enforcer, the Office for Civil Rights (OCR), recently published Director Melanie Fontes Rainer’s presentation from HIPAA Summit 41. The message is clear: cybersecurity is the department’s top priority for 2024.  

 

Prioritizing Investigations: 

The presentation began with a summary of top investigation priorities. Fontes Rainer highlighted that the OCR will focus primarily on cases dealing with the following HIPAA complaints and breach trends: 

• Hacking Incidents 
• Ransomware Attacks 
• Right of Access Enforcement Initiative 
• Risk Analysis Enforcement Initiative 

These priorities emphasize the importance of continuous cybersecurity training for all healthcare employees, as human error is the #1 cause of hacking and ransomware incidents.  

We already know that cybercriminals are opportunistic and do not only target large corporations. Now, the OCR has made it clear that they will also audit *any* organization that has a cybersecurity incident.  

 

Best Practices for Healthcare Data Security: 

Very usefully, the presentation also covered best practices for covered entities and business associates to follow when using technology.  

Vendor and Contractor Relationship Review: 

Begin by reviewing all vendor and contractor relationships to ensure that Business Associate Agreements (BAAs) are in place where appropriate. These agreements should comprehensively address breach and security incident obligations to safeguard PHI effectively. Be sure to review them regularly to ensure that terms have not changed.

Integration of Risk Analysis and Management: 

Integrate risk analysis and risk management seamlessly into business processes. Conduct regular assessments and ensure that they are performed whenever new technologies or business operations are planned. This proactive approach helps identify vulnerabilities and mitigate potential risks effectively. 

Timely Disposal of PHI: 

Dispose of PHI stored on media and paper promptly and securely. Develop protocols for identifying and disposing of PHI that is no longer needed, ensuring that sensitive information is not left vulnerable to unauthorized access. However, remember to not dispose of anything for the retention requirements in your state.

Incorporation of Lessons Learned: 

Continuously incorporate lessons learned from security incidents into the overall security management process. Analyze past incidents to identify weaknesses and implement necessary improvements to strengthen the security posture. 

Comprehensive Training Programs: 

Provide comprehensive training programs tailored to the organization’s specific needs and job responsibilities. Regular training sessions and simulated phishing campaigns should reinforce the critical role of every workforce member in protecting privacy and security. By empowering employees with the knowledge and skills they need, organizations can create a culture of security awareness and accountability. 

 

Conclusion: 

As healthcare data security continues to evolve, adhering to these best practices will only become more important. By implementing robust security measures, conducting regular risk assessments, and providing ongoing training, covered entities and business associates can stay ahead of cybercriminals and their latest tactics.