In the digital age, safeguarding electronic Protected Health Information (ePHI) is paramount for healthcare organizations. HIPAA regulations mandate strict measures to ensure the confidentiality, integrity, and availability of patient data. While attention often focuses on securing servers, computers, and mobile devices, there are lesser-known pieces of equipment that can store ePHI and pose significant risks if overlooked.
Let’s delve into some of these often-forgotten equipment types and explore real-world examples where their neglect led to HIPAA breaches or violations.
- Multi-Function Printers (MFPs)
Multi-function printers, commonly found in healthcare settings for printing, scanning, and faxing, often store copies of documents that pass through them. If not properly configured and secured, these devices can become repositories of sensitive patient information.
Example: In 2016, an investigation by the U.S. Department of Health and Human Services Office for Civil Rights (OCR) found that a healthcare provider’s failure to implement security measures on their MFPs resulted in unauthorized access to ePHI. This violation led to a settlement of $2.14 million.
- Photocopiers and Fax Machines
Similar to MFPs, standalone photocopiers and fax machines may retain images or copies of documents containing ePHI, posing a risk if not adequately protected.
Example: In 2018, a healthcare organization faced a HIPAA violation penalty of $100,000 for leaving photocopiers unsecured in a vacant hospital. These devices stored ePHI, and their neglect contributed to the breach.
- Voice Recorders and Dictation Systems
Healthcare professionals often use voice recorders and dictation systems to capture patient notes and medical records verbally. If these devices store recordings without encryption or access controls, they can expose sensitive information.
Example: In 2019, a medical transcription company experienced a data breach affecting over 200,000 patients when unencrypted voice recordings were exposed online. The lack of security measures on the dictation systems led to the unauthorized disclosure of ePHI.
- Wearable Health Devices
With the rise of wearable technology in healthcare, including smartwatches and fitness trackers, individuals can track their health metrics conveniently. However, these devices may sync data with smartphones or cloud services, potentially storing ePHI that requires protection.
Example: In 2020, a healthcare provider faced scrutiny after a nurse posted patient information on social media. Investigations revealed that the nurse had accessed ePHI using a fitness tracker synced with their smartphone, highlighting the need for better security protocols around wearable health devices.
Conclusion
While healthcare organizations diligently implement security measures for traditional IT infrastructure, overlooking lesser-known equipment that stores ePHI can lead to costly HIPAA violations and breaches. Multi-function printers, photocopiers, voice recorders, and wearable health devices are just a few examples of these overlooked hotspots.
To mitigate risks, organizations must conduct comprehensive risk assessments to identify all potential ePHI storage points, implement encryption and access controls, regularly update security protocols, and provide ongoing staff training on HIPAA compliance. Luckily there are companies like Taino Consultants and EPI Compliance that can help you with these tasks. For example, Taino Consultants has a team of Certified HIPAA Security Officers that can conduct your SRAs while EPI Compliance has a whole compliance suite that provides policies, fillable forms to guide and help with the documentation process, monthly checklists, training, and security reminders throughout the year.
Keep in mind that if you are going to “play” the game you must follow the rules.