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HIPAA Considerations


HIPAA Considerations

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Jim Mace
Jim Mace
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I am working on a proposal for setting up a HIPAA compliant Web application with a SQL Server 2005 backend, and I have a couple of questions for those of you who work in an environment where you administer a database for a Web application front end. What are some network topology considerations that you have found to be very beneficial (i.e. placing hardware/software firewalls, routers, and intrusion detection devices between Web server and the data server). As far as PHI is concerned, what do you have encrypted, if anything, in the data tables? Most of what I have read concerns encryption over the wire in an "open" environment, but never gives any real specifications as to algorithms and the like. I was just wondering on what some of the considerations you all take.

Thanks in advance,
Jim
TheSQLGuru
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I don't recall there being a requirement to encrypt data within an 'appropriately protected' network. I do recall 128bit encryption being the minimum for external data transfer over open connections (FTP, HTTP or the like). I don't know if the standards have been updated - haven't reexamined them in years. I have a healthcare client and they have no encryption within their SQL Servers (VERY important to not do this for performance concerns) and use HTTPS to present PHI-containing data to their clients via a web interface. EDI and other data load files are sent either using a proprietary file transfer system or PGP-encrypted FTP transfers. Data between the middle tier, web servers and sql servers is not encrypted since all of these reside behind a robust commercial firewall system.

Best,
Kevin G. Boles
SQL Server Consultant
SQL MVP 2007-2012
TheSQLGuru on googles mail service
Yelena Varshal
Yelena Varshal
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It is really very important in the regulated environment to protect data, in your case probably patient's privacy. What makes a difference is whether the web server is outside of the company network (in DMZ) or it is on the network. For DMZ web servers I would not send unencrypted passwords etc. and would set up SSL. For the web server on the internal network, I would care more about other requirements, like unique logins, backup encryption and general backup security, web application quality (if it does not allow SQL injections) etc.


Regards,
Yelena Varshal

bnordberg
bnordberg
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The main thing for HIPAA compliance is documentation. Do a risk assessment and document what you are doing to protect the data. Encrypt anytime it goes outside your network, then do a risk assessment of your network to determine if you need internal encryption. I have many web/sql apps. We have a hardware firewall and IDS. Becasue of our firewall, I don't expose our data to the Internet. On the web server I have SSL to encrypt. In IIS, I limit the IP space that can communicate to the box. Our server room routers have access rules that only allow the web box and a few other IP's to directly connect to the SQL box. All clients connecting to SQL must use an AD account that follows our hardening requirements (length, special character, history...) I encrypt SSN on the backend, but that is it.



mitch-807519
mitch-807519
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I'm not sure if anyone will read this as it is a fairly old topic but what do I use if I am using DTS packages to transfer result sets from one location's DB to another's?
bnordberg
bnordberg
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How is the data moving from one location to the other? Is there a VPN? If so the VPN should create an encrypted tunnel that the data go across. But if your going across the public internet you need to encrypt on both ends - that could be ugly.



rwaidmann
rwaidmann
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Jim,

Our company does a fair amount of hosting for HIPAA environments, and we've been audited before by our HIPAA clients (and their auditors) and they have been found to be in compliance. We have a division called REDPLAID Managed Hosting that has developed a HIPAA Compliance Support Plan, that our clients have found to be helpful in setting up an appropriate environment and achieving HIPAA compliance. It includes the following:

REDPLAID HIPAA Compliance Support Services
* Enhanced Access Protection
* Enhanced Firewall & VPN Support
* Support For Advanced Data Encryption
* Enhanced Password Management
* Detailed Audit Tracking
* Encrypted Offsite Backups
* Data Destruction Services
* Recording Of Data Movements
* Facility Logs & Audits
* Vulnerability Scanning For 70,000+ Vulnerabilities
* Managed F-Secure™ Server Antivirus Protection
* Advanced Network Intrusion Prevention (IPS)
* Advanced Server Intrusion Prevention With Advanced Correlation Engine
* Advanced Server Hardening
* TripWire™ Server Integrity Monitoring W/Auto Rollback
* NetZentry CleanTraffic™ Distributed Denial Of Service (DDoS) Protection

https://www.redplaid.com/hipaa_hosting.html

If you want to have it hosted externall, this may be an option. Best of luck!
anoel
anoel
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Speaking of HIPAA, I'm working with a medical provider that needs to produce EDI files (specifically form 837 for Medicaid claims). They transmit the file manually so they only need a tool that will take the data from a .txt file and create a properly formatted EDI file. I've searched the web 10x's over and all I can find are companies that create a full-blown application that integrates with accounting software. I can start from scratch but from what I've read, that's a COMPLETE nightmare. ANY help or guidance would be greatly appreciated.

Thanks,
Amy BigGrin



venus0502
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Amy,

I am not sure if you are still looking for a system to help with your 837 EDI file creation. But Remora ICE system is a stand alone system that can import a .txt file and generate and 837I or P 4010A or 5010 for transmission. It is also HIPAA compliant. You can contact edi_trainer@yahoo.com for more information........Venus
venus0502
venus0502
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Amy,

I am not sure if you are still looking for a system to help with your 837 EDI file creation. But Remora ICE system is a stand alone system that can import a .txt file and generate and 837I or P 4010A or 5010 for transmission. It is also HIPAA compliant. You can contact edi_trainer@yahoo.com for more information........Venus
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