DoD IG Discovers Serious Flaws in Navy and Air Force EHR and Security Systems and Potential HIPAA Violations

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A Department of Defense Inspector General (DoDIG) audit of the electronic health record (EHR) and security systems at the Defense Health Agency (DHA), Navy, and Air Force has uncovered serious security vulnerabilities that could potentially be exploited to gain access to systems and protected health information (PHI).

This is the second DoDIG report from recent audits of military training facilities (MTFs). The first report revealed the DHA and Army had failed to consistently implement security protocols to safeguard EHRs and systems that stored, processed, or transmitted PHI. The latest report, which covers the DHA, Navy, and Air Force, has revealed serious vulnerabilities in 11 different areas.

Inconsistency of implementing security protocols to protect EHRs and PHI, and the ineffective administrative, technical, and physical safeguards deployed constitute violations of Health Insurance Portability and Accountability Act (HIPAA) Rules. Those violations could attract financial penalties of up to $1.5 million per violation category.

The DoDIG visited three Navy and two Air Force facilities and assessed 17 information systems across the five locations.

  • Naval Hospital Camp Pendleton, Camp Pendleton, CA
  • San Diego Naval Medical Center, San Diego, CA
  • S. Naval Ship Mercy, San Diego, CA
  • 436th Medical Group, Dover, DW
  • Wright-Patterson Medical Center, Dayton, OH

3 DoD EHR systems, 3 modified DoD EHR systems, 9 service-specific systems, and 2 DHA-owned systems were assessed.

There were instances where vulnerabilities had gone undetected and many cases of detected vulnerabilities failing to be addressed in a reasonable time frame. In its report, DoDIG said the audit at the 436th Medical Group revealed 342 of the 1,430 vulnerabilities identified in May had not been addressed and appeared in the vulnerability scan conducted in June.

The reason for the failure to consistently implement security protocols and address vulnerabilities differed at each audited site, but were largely due to a lack of resources, a lack of guidance, system incompatibility, and vendor limitations.

Security issues were identified in the following areas:

  • Failure to consistently implement multi-factor authentication
  • Failure to configure passwords to meet DoD length/complexity requirements
  • Failure to address known network vulnerabilities
  • Failures to set privileges based on users’ assigned duties
  • Failure to configure controls to lock EHRs after 15 minutes of inactivity
  • Failure to review system activity reports to identify suspicious activities and access attempts
  • Failure to develop standard operating procedures and manage system access
  • Failure to implement appropriate and adequate security protocols to protect ePHI and PHI from unauthorized access
  • Failure to maintain an inventory of all service-specific systems that stored, processed, or transmitted PHI
  • Failure to develop and maintain privacy impact assessments

“Without well-defined, effectively implemented system security protocols, the DHA, Navy, and Air Force compromised the integrity, confidentiality, and availability of PHI”, wrote DoDIG in its report. “Security protocols, when not applied or ineffective, increase the risk of successful cyberattacks; system and data breaches; data loss and manipulation; and unauthorized disclosures of PHI.”

DoDIG made several recommendations to improve security which included configuring systems used to store, process, or transmit ePHI to lock automatically after 15 minutes of inactivity; the development of an oversight plan to ensure recommendations are applied across all locations; actions to be taken to address vulnerabilities in a timely manner; implement procedures to only grant access to systems used to store, process, and transmit Phi based on users’ responsibilities.

DoDIG also recommended the Surgeons General for the Departments of the Navy and Air Force coordinate with the Navy Bureau of Medicine and Surgery and the Air Force Medical Service to assess whether the issues discovered exist at other service-specific military training facilities.

On the whole, the recommendations were accepted, although at certain locations some recommendations remain unresolved and require additional comments.

The DHA Director agreed that the DHA could potentially configure systems to lock after 15 minutes of inactivity, but did not provide assurances that its systems would be changed to incorporate that control.

The Executive Director for the Naval Medical Center, San Diego disagreed with one recommendation. The Military Sealift Command Chief of Staff partly agreed with two recommendations and disagreed with one, but suggested additional controls and alternate actions that could be taken to address all recommendations for the USNS Mercy.

Author: HIPAA Journal

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