Re: HIPAA security requirements

[ONEILL David J <David.J.Oneill () state or us>]

Matt,
I work for the State of Oregon as a Web Application Developer and have been to
several HIPAA classes <yech>.  Because I am employed by the state, I am not a
good source for your contract questions.

One misnomer is that you can not display patient information, your application
can show that information.  It is the transfer of information from one
environment to another that gets touche.  The rule of thumb is that you strip
out an information that can pinpoint an individual (SSN, medical ID#, Full
Name, Street Address, ...) when transmitting thru unsecured channels.  All
other information is fair game for transmission.  If the data channel is
encrypted(64bit or better), no worries.

Fortunately for us developers, most of the data security work is the
responsibility of the data consumer.  They need to make sure no one is looking
over their shoulder, grabbing their printouts, sitting in a park under a
security camera, so on and so forth.  I'm sure you get the picture.

Looking into the future, I think that you can rest assured the if you do due
security diligence now you should be safe.  Clauses such as "warrantied
against volnerablities and exploits that are know as of <data>" would most
likely cover you for most issues.  This way the customer does not get the idea
that you are warrantying against what is unknown.

Hope this helps,



David J. O'Neill
Senior Systems Analyst
Parkway Bldg., 2nd Floor
Phone: (503) 378-2101 ext. 364
FAX:     (503) 378-2103

> > > president () sheergenius com 01/15/04 03:13PM >>>
Howdy,

I've been lurking on the list now for over a year and wanted to start my 
first post by thanking everyone out there who has been answering 
questions and has contributed to all of the wonderful projects I've 
heard about on the list.  My hat is off to all of you for being such 
talented professionals and still managing to give back to the community 
with your efforts.

Now, on to the feature:

I was wondering if anyone has come across any specific requirements that 
are implicit or even implied by the security-related portions of the 
HIPAA act, including amendments.  As a web application developer, I have 
to assure my healthcare clients that we will strive to meet HIPAA 
requirements, but have never come across any document or analysis that 
tries to bring into focus what precisely that means in the context of 
database-backed web applications.  Some things are obvious:  If your app 
does absolutely anything that could expose patient information to the 
wrong eyes, that would fall astray.  Others are not quite as obvious.  
Also, after a contract has been completed, if new exploits are 
discovered, what are the developer's ongoing responsibilities?  Is the 
developer forever obligated to point out new security weaknesses so that 
the client can opt to hire someone to fix them?  If not, where does the 
liability end?

Does anyone know of any such document, discussion, or guidance?  Care to 
start one?  I'll help.

I should note that my thinking on this was jump-started by the 
interesting column currently featured on owasp.org by Jeff Williams.  I 
should also note that I could only read what was on that first page, as 
the link for more of the story seems to be broken right now.

Thanks,

Matt Kenigson
president () sheergenius com