The Role of IAM in HIPAA/HITECH Compliance

I recently authored a white paper entitled, “Identity and Access Management – Enabling HIPAA/HITECH Compliance.”  The paper is now in the final editing and formatting process.  As we awaiting the final publishing date, let me share an excerpt from the paper, focused on the key ways IAM enables HIPAA/HITECH compliance.

HIPAA/HITECH requirements for privacy, security, auditing and notification are supported directly by IAM. By streamlining the management of user identities and access rights and automating time-consuming audits and reports, IAM solutions can help support strong privacy and security policies across the enterprise and throughout Health Information Networks while reducing the overall cost of compliance.

IAM provides the following key enablers for HIPAA/HITECH compliance:

  1. Assign and control user access rights. Securely managing the assignment of user access rights is critical to HIPAA/HITECH compliance, particularly in distributed and networked environments typical of modern healthcare business. Decentralized provisioning is not only inefficient and costly, it also increases the risk of security and privacy violations. Automated provisioning allows centralized control of resources and applications that have historically existed in silos. This provides a much greater level of control over access to those resources. Checking audit policy at the time or provisioning ensures regulatory compliance, thus preventing audit policy violations.

  2. Adjust user access rights when responsibilities change. Business risk is introduced when employees change jobs and access isn’t appropriately adjusted or removed. Failing to appropriately adjust or remove users’ access when job changes occur can result in superuser-access and SOD violations. Automated provisioning effectively eliminates many of these risks, especially when combined with auditing and role management capabilities.

  3. Revoke user access upon termination. IAM systems can automate the process of immediately revoking user access rights upon termination or suspension. This eliminates a commonly-exploited security gap and opportunity for policy violation that may occur after an employee or contractor has been dismissed.

  4. Manage allocation of user credentials. Managing user names, passwords and other user access credentials is essential to assuring that only authorized users are granted access to information systems. IAM technology can provide enterprise-wide control of user credentials, including the enforcement of uniform password policies (e.g. password strength, periodic change).

  5. Enforce segregation of duties (SOD) policies. Segregation of duties (also known as separation of duties), has as its primary objective the prevention of fraud and errors. This objective is achieved by disseminating the tasks and associated privileges for a specific business process among multiple users. IAM methods can prevent, detect, and resolve access rights conflicts to reduce the likelihood that individuals can act in a fraudulent or negligent manner. Once violations are identified, notification and remediation steps are automatically initiated based on corporate policies.

  6. Provide uniform access policy. IAM can provide administration and enforcement of common user access policies across a wide span of diverse systems, improving executive confidence in how the enterprise complies with HIPAA/HITECH requirements.

  7. Manage access based on business roles. Provisioning and auditing at the business role level, rather than just at the IT access control level, ties user access rights more closely to business processes. With a role management solution, managers can approve access rights that have a meaningful business context, thus reducing the risk of managers inadvertently creating SOD violations by granting carte blanche access to their direct reports.

  8. Enforce secure access policies. While automated identity administration, provisioning and auditing are essential to HIPAA/HITECH compliance, these methods don't actually enforce the use of security policies when a user accesses the controlled systems. IAM Access Management technology can enforce user access policy at the point of entry to an application or other system, in harmony with established policy. Examples of such enforcement include Web access management (including single sign-on or SSO), enterprise single sign-on (ESSO), and Web service security.

  9. Enforce informed consent principles. Informed consent principles (e.g. opt-in, opt-out, notice) can be enforced, based on identities of individual patients and potential users of personal information associated with such data.

  10. Extend access control to business associates. Identity Federation can extend access control beyond enterprise boundaries to enable secure access to electronic records while safeguarding the privacy of sensitive information. This is essential to complied with extended requirements of HITECH.

  11. Verify access rights. While automated user access provisioning is designed to accurately assign access rights, such access rights should be confirmed by audit. IAM can provide the ability to both assign access rights according to established polices and then periodically verify that access rights are still compliant with those same policies.

  12. Conduct periodic compliance assessments. Periodic audits of access rights and privileges can assure that security and privacy policies are consistently enforced. Re-certification is a process where managers approve direct reports’ access to enterprise resources and applications. IAM can provide the ability to automatically present managers with the correct information to attest to each employee's access rights needs. By applying role management principles, this re-certification process can enable the approving manager to work at the business-role level, attesting to those entitlements quickly and accurately because they are given in a meaningful business context.

  13. Provide automated reports. The delivery of accurate, timely and complete reports can assess compliance with established requirements. IAM can provide scheduled and ad-hoc compliance reports, including automated violation notifications, comprehensive work flow processes, and audit assessment reports. Such reports can generated across multiple systems and enterprise applications and be submitted to appropriate people within the enterprise, to business associates and to appropriate regulatory agencies.

I’ll share more excerpts soon and let you know when the full paper is ready for download.  Please stay tuned.

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About

Discovering Identity was founded on blogs.sun.com in May 2005 as a means of documenting my exploration of the field of Identity and Access Management. In February, 2010, I switched to hosting the blog at DiscoveringIdentity.com. In March 2012, I began posting Oracle-related information in both places.

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The views expressed on this blog are my own and do not necessarily reflect the views of my employer, Oracle Corporation, or any other person or organization.

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