We are looking for a good Systems Administrator for a New York City client.  If you know someone that might be a good fit please pass the below posting to them.

Systems Engineer/Systems Administrator

Joplin, MO was hit by a massive tornado on Sunday evening that did extensive damage to the St. John’s Regional Medical Center hospital. There are reports that x-rays from the hospital have been found in driveways 70 miles east of the hospital.

On Twitter Steven Waldren sheds some very interesting and insightful perspectives:

Steven’s quotes gets to the bottom of Disaster Recovery.  When an actual disaster hits and your servers are destroyed how do you get to your data? Having tape backups or offsite backups are fine but if your servers are gone where do you restore the data?

Disaster Recovery (DR) planning is more than ensuring you have a backup of your data. It is about ensuring that your organization can still function and get to critical systems even when your primary systems have been destroyed. With cloud-based Disaster Recovery solutions the cost of implementing DR has been significantly lowered. All healthcare organizations should be looking into some sort of DR that will not only ensure that data is properly backed up but will allow for access to critical data in the event of a real disaster.

Contingency planning and DR planning are required under the HIPAA Security Rule:

STANDARD § 164.308(a)(7)Contingency Plan

The purpose of contingency planning is to establish strategies for recovering access to EPHI should the organization experience an emergency or other occurrence, such as a power outage and/or disruption of critical business operations. The goal is to ensure that organizations have their EPHI available when it is needed. The Contingency Plan standard requires that covered entities:

“Establish (and implement as needed) policies and procedures for responding to an emergency or other occurrence (for example, fire, vandalism, system failure, and natural disaster) that damages systems that contain electronic protected health information.”

DISASTER RECOVERY PLAN (R) – § 164.308(a)(7)(ii)(B)

The Disaster Recovery Plan implementation specification requires covered entities to:

“Establish (and implement as needed) procedures to restore any loss of data.” Some covered entities may already have a general disaster plan that meets this requirement; however, each entity must review the current plan to ensure that it allows them to recover EPHI

A final takeaway is that the time to think about Disaster Recovery is before a disaster hits. Implementing DR is not only required under HIPAA but is critical to any business to ensure that the organization can continue to operate even when primary systems are destroyed.

It seems that at least twice a month we are hearing about a health care organization that has had a data breach because of a lost of stolen laptop. Every time I read about a new breach I shake my head and ask myself why aren’t these organizations using encryption to protect the contents on the laptops? I have come up with 2 conclusions:

1. The organizations are not familiar with encryption technology and think it is too complex to implement
2. The organizations think that implementing encryption technology is too expensive and cost prohibitive

So I thought I would take a few minutes to hopefully help enlighten some people on just how easy it is to implement encryption and how affordable encryption is.

There are many encryption products on the market.  Some are free such at TrueCrypt, while others vary in cost and complexity.  PGP is one of the leaders in encryption and has recently been purchased by Symantec Corporation.  PGP ranges from encryption of a few laptops to 1,000s of laptops in an enterprise.  PGP usually requires some infrastructure setup that allows administrators to control policies, safeguard encryption keys and monitor which laptops have been encrypted. There is some complexity that is associated with setup and deploying PGP encryption.

A product that we have been using for ourselves and our clients is called AlertBoot.  AlertBoot is an easy to install encryption product that encrypts the entire laptop’s hard drive.  The install is web based from the AlertBoot’s site and is very easy and painless.  Depending on the size of the hard drive and the speed of the drive it can take anywhere from 30 minutes to 4 hours to encrypt the drive.  You can even use the laptop while it is doing the one-time encryption.  There is no risk of losing the encryption password and then being locked out of the laptop.  AlertBoot has 7×24 hour support that can help a user recover a lost encryption password.

AlertBoot Support, Password Recovery, and Helpdesk

Forget your password? Have a question about AlertBoot? Don’t worry: help is always just a phone call away. AlertDesk is your personal helpdesk for password recovery and assistance— open 24 hours a day, 7 days a week, 365 days a year.

AlertDesk is completely secure and confidential. You’ll be challenged with security questions as a safety precaution to verify your identity. AlertDesk Support will never have access to your devices or your personal data.

AlertBoot encryption costs $12.95 per month per laptop.  There is a 10% savings if you prepay for the year.  So for around $150/year per laptop you can fully encrypt the contents of the hard drive.

Now to be clear, AlertBoot is just one of the many products on the market and I am only using them as an example because I am familiar with the technology and their monthly cost per laptop makes it easy to calculate the true cost of encrypting each laptop.

So say you have 10 laptops in your organization, you are looking at $130 month to encrypt all 10 laptops.  That to me is a very reasonable price to pay to ensure that you are protecting the data on each laptop, complying with HIPAA regulations and ensuring that any patient data on the laptop is secure and protected.

To put the costs into perspective let’s take a look at some estimates of cost if a laptop is lost or stolen.  According to the Ponemon study (PDF) titled “The Cost of a Lost Laptop” published in April 22, 2009, a lost laptop will cost:

According to the report, the use of encryption can reduce the cost of a lost laptop by $20,000. That makes the $12.95/mo seem incredibly cheap.  And now that you know encryption is easy to install and the risk of being locked out of the laptop is not an issue, you should seriously consider encrypting each of your laptops. There really is no good excuse not to implement Laptop encryption.

Medical practices are not only tasked with protecting their patient’s health but now are responsible for protecting their patient’s electronic information as well. Protecting data is probably something that most practice employees have not been trained to do nor are they familiar with best security practices. Data security is usually left to IT consultants who maintain and support their network.  Here are 5 things that you and your IT consultants can do to ensure you are properly protecting patient data.

Security Patches

The reality of software is that most software has security vulnerabilities that allow hackers, viruses and spyware to exploit these vulnerabilities and compromise the security of a network. Software vulnerabilities are in Windows operating systems including desktops (Windows XP, Vista and 7) and servers (all versions). Software vulnerabilities are also in applications such as Adobe Acrobat, Microsoft Office, and Internet Browsers. In order to minimize the risk of software vulnerabilities, vendor security patches should be diligently applied.  Microsoft issues patches at least once a month.  These patches should be applied by your IT vendor.  Desktops can be set to automatically update with no need for IT or user intervention.  Employees should be trained to diligently update programs such as Adobe Acrobat and Flash, Java and Internet Browsers. An even better strategy is to invest in software that allows IT administrators to control the deployments of vendor security patches and software updates. Microsoft has free tools to control Microsoft specific security patches to be centrally deployed. Unfortunately the Microsoft tools do not take care of 3^rd party applications.  Additional tools will need to be purchased to address these 3^rd party apps.

Ban USB drives

A majority of patient data security breaches are due to lost or stolen portable devices such as USB drives, smart phones and laptops. In order to reduce the risk of a data breach, I recommend that you set a policy to ban USB drives. If an employee absolutely needs to use a USB drive to perform their job function then invest in encrypted USB drives. I am a fan of the Kanguru encrypted drives.  You can also get other encrypted drives here. Many people I talk to about data encryption admit to me that they really don’t understand the technology and are reluctant to use it because of this.  Simply stated an encrypted USB drive secures the data on the drive and requires a password to read or write information to the drive. The technology is super easy to use.  These drives cost more than unencrypted drives but the cost is not significant.  For example an unencrypted 4GB drive might cost $10 and an encrypted drive might cost $35.  The cost difference is nothing compared to the cost of a data breach.

Encrypt Laptops

As mentioned above, stolen or lost laptops are a leading cause of data breaches. All laptops should be encrypted. There are many types of encryption on the market. Some of these require IT support and installation. An encryption service that we started to work with called AlertBoot sells a very easy to use product that will encrypt a laptop’s disk drive. The service can be used with no IT support required. After AlertBoot encrypts the laptop’s disk drive, an employee simply enters the encryption password once each time they start the laptop. AlertBoot can help reset the encryption password if an employee forgets it so there are no worries about losing a password and being locked out of the laptop. At $12.95/mo. it is not the cheapest on the market but its ease of installation, minimal impact to a laptop’s performance and 7 x 24 hour support make it a great choice to protect each of your laptops.

Password Controls

One of the cheapest and most effective security steps that you can do is to implement passwords controls.  Password controls include:

• Disabling a user account after a number of failed password attempts (think 5 failed passwords and your account is locked and can only be unlocked by your IT administrator)
• Require complex passwords. Simply stated, complex passwords require a user to set a password that is 6 -8 characters and must have letters, numbers, and special characters (! @ # $ % ^ & * + ).  These prevent using easy to guess passwords.
• Force users to change passwords every 60-90 days. Unfortunately I can guarantee you that your employees will complain about this. It always amazes me how people hate to change their passwords. I guess with so many different passwords, changing one makes it even harder to remember them. As a note, security is a fine balance between protecting your network and making it easy for employees to perform their job function.

Each of these password controls can easily be set by your IT administrator using the tools that Microsoft provides to manage a Windows networks.  At most this setup will take 1 or 2 hours of time.

Encrypt Backup Tapes

Backing up your data is very important and is a best practice to ensuring that you protect your patient’s information. If you backup your EMR on a nightly basis you will have all of your patient’s records on the backup tape.  That can be 100, 1,000 or 100,000 patients depending on how much data is in your EMR.  Now think about what would happen if that backup tape is lost or stolen.  Having the tape lost or stolen is not that hard to imagine and could happen if someone breaks into your office or if an employee is responsible for taking the tape out of the office and has it stolen from their car.  The good news is that most backup software has data encryption built into the software.  All that has to be done is to configure the software to encrypt the data and set an encryption password.  Unfortunately what I have seen is that the encryption setting is usually not set and the data is backed up to tape without encryption. Make sure your IT vendor has encryption enabled and that your tapes are encrypted.

If you follow these 5 steps to securing your patient’s data your will significantly increase your level of security.  As I mentioned, none of these are very expensive and the expense is insignificant compared to the expense of a data breach.  And as an added benefit, these will help you with your HIPAA security compliance as well.

Let me know if you already have implemented some of these security measures or if you have other examples of easy and cheap security protections.

Image: jscreationzs / FreeDigitalPhotos.net

You have just implementing a new electronic health records (EHR) system, congratulations!  You probably spent anywhere from $75,000 – $500,000+ on hardware, software, licenses,and implementation labor.
Hopefully you qualify for EHR meaningful use incentive funds to offset some of those expenses. While you are looking to stop spending money and to start recouping some of the expense, I am going to tell you 3 additional products and services that you must consider.

The 3 products and services are:

1. Offsite data backup
2. HIPAA Security
3. Disaster Recovery

I realize those 3 items are not sexy and will not help increase your revenue. I think that is one of the reasons that many medical practices don’t sign up for these services. The 3 services are about protecting your EHR, your data, your patient’s information and protecting your practice.

Offsite Data Backup

“Why do I need offsite data backup when we are backing up to a tape drive?”

I can’t tell you how many times I have had this conversation. Backing up your data nightly to a tape drive is a good practice but unfortunately backup tapes are not completely reliable. Every time we have to restore a file, database or other data from a backup tape, I hold my breath and pray that the data is on the tape and we can retrieve it successfully.

If you are backing up to tape the responsibility to switch tapes on a daily basis is usually assigned to an individual in the practice. From experience we have seen that people forget to switch tapes (trust me this happens more then you can imagine). In addition, tapes are used over and over and eventually they lose their ability to successfully read and write data. Hence the praying comment that when we need the data, the tape will not be at the point where we can not successfully retrieve the data.

Offsite data backup is a very straightforward process and very similar to backing data up to tape. On a nightly basis the data is backed up but instead of being backed up to tape it is backed up to a server in a vendor’s data center. Here is how it works.

1. On the system that you are backing up, there is a backup agent (software program) that starts to backup the data.
2. The backup agent makes a secure encrypted connection via the Internet to a server(s) at a vendor’s data center.
3. The data is copied to the servers and is stored on the vendor’s server is a secure encrypted format.

As you can see it is critical to have an Internet connection in order to perform the offsite backup.  The offsite data backup is scheduled and runs automatically so there is no human intervention required. This eliminates the issue with someone forgetting to change the backup tape.

My recommendation to most practices is to use offsite data backup as a supplemental service in addition to doing nightly tape backups.  If you do both then you have your data in 2 different places and you increase your chances that the data will be available if and when you need it.

On an average, offsite data backup costs around $2/GB.  So if you are backing up your EHR and you have 20GB of data it will cost you around $40/mo. I think that is a very reasonable amount to help ensure that your data is protected. To help convince you that offsite backup is worth the additional expense let’s look at a scenario that I have seen happen multiple times.

There is a really bad storm with heavy rain and lightning. The storm knocks out power to your office and although your EHR server is on a uninterrupted power supply (UPS) the server does not shut down cleanly (immediately loses power) and in the process it corrupts the EHR database. When power is eventually restored and the server comes back online the EHR program generates errors stating that it can not read the EHR database (it is corrupt). Imagine that you have been using the EHR for 1 month and every patient that you have seen is in your EHR (go ahead and imagine you have been using it for over a year and the amount of records would be even scarier). Your IT company comes in to help restore the EHR database from tape and get you back up and running.  When the IT company inserts the backup tape they can not locate the EHR database.   It turns out that the person who was responsible for changing the tape forgot to do it the last 2 evenings. They are able to restore the database from 2 days ago but all the data that was entered for the past 2 days is lost.  Think about having to recreate that data. You are using an EHR so do you have notes on each patient? Probably not. The amount of time and effort you and your staff will have to use to recover from the lost data makes the $40 look cheap.

HIPAA Security

The second service I urge you to consider is HIPAA Security. You are using an EHR and all of your patient information moving forward will be electronically stored. You may also have interfaces with vendors for electronic lab results, digital x-rays, ultrasounds, etc. For each patient there is a lot of electronic information that has to be protected.

Most EHR vendors do not address HIPAA security when they are training employees on the new EHR. If they do it is not in depth and there is a good chance that your employees will not understand what is required by HIPAA to protect patient information.

HIPAA security is about protecting patient data in electronic format. I am recommending you sign up for a HIPAA security service not only to comply with the HIPAA regulations but to ensure that your entire staff is educated on what exactly is required to protect patient data and to understand the best practices for protecting data. More importantly HIPAA security is a defensive measure to help protect your patients and your practice against a data breach. A lost laptop or USB drive with patient information could have serious financial impact on an organization.  Imagine a data breach that costs your practice $1,500,000. If you think that number too high consider the regulatory fines, patient breach notification expenses, lost revenue from patients leaving the practice, IT related expenses to re-mediate the breach, etc.  Even if the expense is half of that at $750,000 it can have a significant impact to an organization. And if you are thinking that your general liability insurance policy will cover most of those expenses you should check your coverage. Most policies do not cover HIPAA related expenses (although there are supplemental insurance policies that do cover HIPAA and cyber expenses).

There are many HIPAA security services on the market but on a whole you should look to accomplish the following:

1. Implement policies and procedures to ensure that patient information is properly protected
2. Perform a risk assessment to understand where you are at risk in protecting patient information and what additional security measures you should implement to better protect the information.
3. Train your entire staff on exactly what is HIPAA security, what they should be doing to protect patient data and what they should not be doing that could put patient data at risk.

HIPAA security will range in costs but for some real numbers this service will cost $1,750 to provide the 3 items above. (Full disclosure, HIPAA Secure Now! is a service of Entegration, Inc.).

As with the justification for offsite data backup, spending $1,750 to help protected you from fines and expenses that could be up to 100 times more expensive seems like a good investment.

Disaster Recovery

The third and final service I will urge you to consider is disaster recovery for your EHR and network.

I will start off by acknowledging that the odds of a disaster are slim but yet we have seen the affects of earthquakes and tornadoes in the past few months. And disasters are not only confined to natural disasters.  Fires and floods occur all the time.  Broken water pipes and sprinkler systems can destroy servers and computing equipment.

What exactly is disaster recovery?  Simply stated it is the ability to continue to utilize your applications in the event that your primary servers, network and applications are either destroyed or made unavailable by some event. Disaster recovery is ensuring that you can run your EHR on another server and access that server in the event of a disaster.

I wrote a detailed blog article on cheap disaster recovery which you should read.  But from a high level view, disaster recovery is:

1. Ensuring that you have another server(s) in another physical location that you can use in the event your primary server is unavailable
2. Data needs to be copied and kept up to date on the server(s) that you will use for disaster recovery
3. A method of accessing the disaster recovery server must be established
4. A detailed procedure must be in place that defines exactly what is needed to utilize the disaster recovery server(s) and what your employees need to do to operate in disaster recovery mode.

If you go back to the blog article that I wrote on cloud based disaster recovery the prices range from around $100/month/server.  So if you need to ensure that have your EHR server and your Domain Controller available in the event of a disaster then it will cost you around $200/mo.

Again let me define a scenario that helps justify the expense.

Let’s assume a water pipe bursts in the office above you and overnight hundreds of gallons of water leak onto your servers, destroying them.  Everything else in your office is wet but usable. After a couple of days of clean up you are ready to see patients but you no longer have functional servers and no functional EHR. You can order new servers from Dell or HP but even with overnight shipping there is a chance you will not receive them for 10-14 days.  Can you go without your EHR for that long? With the cloud based disaster recovery you can be up and running in as little as 4 hours. You can even access the EHR if you need to see patients in another practices’ office while you repair your office. Again I argue that $200/month is worth the expense to provide the safety net and flexibility to recover in the event of a disaster.

Summary

The 3 services that I described will protect your medical practice. Each of the services can be considered a safety net and operational insurance to protect you and to avoid events that can have significant financial impact to your organization. Take a step back and think of how much money you just spent on your EHR. The services that I recommend will cost you under $5,000 the first year (and half of that moving forward) and will help protect your investment in your EHR.

I would love to hear your thoughts and help with any questions you may have. Use the comments section below to give feedback.

Almost like the Earth spinning and no one notices it, there is a major shift in health care IT going on. On the surface you can’t miss the chatter.  Talk of stimulus funds, meaningful use requirements, cloud based EMRs, free EMRs, iPads, smart phones and the list goes on. Hundreds and thousands of medical practices ranging from 1-3 employees up to hundreds of employees are in the process of either evaluating or transitioning to electronic medical records.  And as these organizations continue their transition from paper based records to electronic medical records the impact will be felt for years to come.

It is exciting to be a part of something that will have a lasting impact. But at the same time I think that there will be a lot of fatalities in this process. On the surface the migration to electronic medical records seems pretty straightforward.

1. Select an EMR vendor
2. Purchase equipment
3. Install equipment
4. Train staff
5. Start using new EMR

But the reality is it is far from easy. There are hundreds of EMR vendors; some good, some not so good. EMR implementations fail at a very high rate. The complexity of setting up a network to support an EMR is daunting. Integrating servers, network, tablets, smartphones, lab equipment, etc. can be a challenge at best and a disaster at worst.

And if a practice makes it this far there are the concerns with patient records and HIPAA security. These practices that are new to electronic medical records have not been tasked with protecting electronic assets in the past. This skill set in not easily acquired nor is it cheap. Network and data security is not a part-time job and it should not be added onto to someone’s job responsibility especially if they are not IT savvy.

And will these practices understand the risks of implementing technology to support electronic medical records? Will they implement the appropriate data backup solutions and disaster recovery solutions to ensure that a disaster does not cripple their ability to use and access the electronic medical records? Will they understand that most small businesses never recover from a disaster that impacts IT?  Will they make the appropriate investments to ensure that a disaster does not put them out of business?

It is almost like a herd being led into an ambush, some of these organizations will be among the fatalities.  A failed EMR implementation can cost hundreds of thousands of dollars. Not many smaller medical practices can take that financial impact and still survive.  A data breach or serious HIPAA violation can  have a huge financial impact on an organization. An unplanned for disaster can put an organization out of business.

So as the headlines talk of meaningful use stage 2 and 3, Medicare EHR Incentive Programs, Attestation, the next greatest tablet, mobile health apps, and cloud based EMRs remember that the impact to some health care organizations will be fatal. Can the quest for electronic medical records be similar to a herd being led into an ambush? Will we look back and see that 2011-2013 led to a thinning of the herd? Will these fatalities lead to more hospitals and larger organizations consolidating smaller medical practices? Electronic medical records are needed and provide an enormous opportunity for the entire health care system but without proper guidance and support many medical practices will be causalities in the process.

On April 21, 2011 Amazon’s East Coast data center went down and brought many high profile businesses down with them. Some of the businesses that rely on Amazon to provide their infrastructure include Foursquare, Quora, Hootsuite, SCVNGR, Heroku,  and Reddit.  In addition small or mid-size businesses that relied on Amazon felt the impact as well.

So a day later we take a step back and look at the impact.  Let’s ask some questions:

First question: Will this signal the end of cloud computing?  NO!

Second question:  Will this be the last cloud based provider to experience an outage? NO!

Third question: Will this harm the migration to cloud based providers? YES!

The first two questions are easy.  The outage is not the first and will not be the last. The benefits of cloud computing to startups, small and mid-size businesses are real and this outage will not signal the end of cloud computing. But the high profile outage may harm the migration to cloud computing.

If you are a medical practice and are in the process of purchasing an EMR for your practice, yesterday’s Amazon outage gives you something to think about. Many EMR vendors give multiple options for deploying the EMR including on-site servers that are in the practice’s office and hosted servers or applications that are at the vendor’s data center or some other hosting facility. A day after Amazon’s outage you have to ask yourself; if Amazon can suffer a complete melt down of their data center what is to stop an EMR vendor from having the same experience? You may even conclude that Amazon, one of the leaders in cloud computing, have far more resources to support their data center than an EMR vendor does.  Does this make you think that the likeliness of an EMR vendor having a prolonged outage is even greater than Amazon having one? I would answer yes. And if you do answer yes, the next question you have to ask is; can you afford to be without your EMR for 24 or more hours?

I think Amazon’s outage will impact migration to cloud based computing. It will not stop cloud based computing but it is a wakeup call for businesses that are looking to use or are currently using cloud based computing. My advice remains the same as it has been in the past. Migrate non-core functions and servers to the cloud and keep core functions and servers within your network / office. There are real benefits to utilizing cloud based services but the risk is just as real. Yesterday’s outage makes that perfectly clear.

Image: Jennifer Ellison / FreeDigitalPhotos.net

I spoke with a potential client today and had a conversation that I seem to be having a lot lately. The client gave an overview of their issues and it with something like this….

Potential Client: “Our network is really screwed up. We have been through 5 IT people already. We installed an EMR but it is a bunch of junk. We are getting a new EMR in a few months. We spent $44,000 on the first EMR and even more on the second. We can’t add new laptops, we can’t print. We need help.”

The good news is that the problems he mentioned to me all seem to be very straightforward and fixable. I let him know that the first thing that has to be done is to ensure that the network is operating correctly before any EMR is installed.

As I mentioned this is the same conversation that I have had over and over. It seems that so many medical practices are implementing advanced technologies to support EMRs but operating on networks that are not up to specs or configured correctly. In addition, the EMR software does not perform the way the vendor stated and does not provide the functionality they are looking for.

One of the core functions we do for our clients is to help them with software and hardware selection. A client that is evaluating an EMR needs help to ensure that the EMR will work in their environment. They need technical guidance to ensure the infrastructure can support the new EMR. A lot of EMR vendors try to undersell the hardware requirements to make their products look more affordable. I think this is a huge mistake. It is critical to ensure that the network is properly sized, configured and ready to run an EMR.