Addressing Security and Compliance in Custom EHR Development

The healthcare landscape is witnessing a surge in custom EHR development, with the global market expected to be a staggering $40 billion market by 2026. This shift towards tailor-made solutions reflects a desire for better workflow integration, improved data management, and enhanced patient engagement. However, amidst this exciting transformation, one factor remains paramount: security and compliance.

Recent statistics underscore the criticality of robust data protection in healthcare:

• A breach of protected health information (PHI) costs an average of $499 per record, highlighting the financial consequences of lax security measures.

• Data breaches in the healthcare sector increased by 58% in 2022, signifying the growing risks for organizations.

In this context, custom EHR development presents both opportunities and challenges. While increased flexibility allows for tightly integrated security protocols, the custom solutions also require meticulous compliance adherence.

In this blog, we will delve into the intricacies of safeguarding patient data within custom EHR environments.

Let’s get started.

Understanding the Regulatory Landscape:

Developing a custom EHR requires navigating a complex web of regulations designed to protect patient privacy and data security.

Here’s a breakdown of key regulations and their importance:

1. HIPAA (Health Insurance Portability and Accountability Act)

• Core requirements: HIPAA (Healthcare Insurance Portability and Accountability Act) safeguards the Protected Health Information (PHI) of patients in the US. It sets standards for secure storage, transmission, and access control of PHI, requiring data encryption, risk assessments, and breach notification protocols.
• Objectives: To ensure the privacy rights of patients and prevent unauthorized access to PHI.

2. GDPR (General Data Protection Regulation)

• Core requirements: GDPR applies to any organization processing the personal data of EU citizens, regardless of location. It mandates strong data protection principles like transparency, purpose limitation, and the right to erasure.
• Objectives: To empower individuals with control over their personal data and strengthen EU data protection law.

3. HITRUST CSF (Health Information Trust & Assurance Resource Center)

• Core requirements: HITRUST CSF is a voluntary framework offering a comprehensive set of security controls for protecting PHI. It aligns with various regulations like HIPAA and GDPR, aiding compliance efforts.
• Objectives: To enhance the security posture of healthcare organizations and provide a standardized approach to managing risk.

4. HITECH (Health Information Technology for Economic and Clinical Health Act)

• Core: Incentivizes adoption of EHRs and promotes “Meaningful Use (MU)” of health IT for improved care quality.
• Objectives: Drives electronic health information exchange and improves healthcare quality through EHR utilization.

5. ONC (Office of the National Coordinator for Health IT)

• Core: Establishes standards and promotes nationwide interoperability of health data.
• Objectives: Enables seamless health information exchange between EHR systems and providers.

6. CMS (Centers for Medicare & Medicaid Services)

• Core: Sets specific EHR certification requirements for participation in Medicare and Medicaid programs.
• Objectives: Ensures EHRs meet minimum functionality and data standards for healthcare reimbursement.

Importance of Staying Updated:

The regulatory landscape for healthcare IT is constantly evolving. Staying informed of changes and emerging standards is crucial for:

• Compliance: Avoid potential legal and financial penalties for non-compliance.

• Data Security: Minimize the risk of data breaches and protect patient privacy.

• EHR Functionality: Ensure your EHR aligns with evolving interoperability and meaningful use requirements.

• Market Advantage: Adapt to new compliance standards and stay competitive in the dynamic healthcare IT market

Additional Considerations:

• Location: Regulations vary based on your location. Consider additional rules like PIPEDA (Canada) or APAC-specific requirements.

• Data flow: If your EHR processes data across borders, understand regulations affecting each region.

• Professional guidance: Engage legal and compliance experts to navigate complex regulations and stay informed.

Integrating Security throughout the Custom EHR Development Lifecycle

Developing a custom EHR involves handling sensitive patient data, making security paramount. Integrating security throughout the entire development lifecycle is crucial to protect this sensitive information and build trust with patients and healthcare providers.

Let’s delve into some key elements:-

1. Security Coding Practices and Vulnerability Management:

Developers should adopt secure coding methodologies like OWASP Top 10 to prevent common vulnerabilities like SQL injection and cross-site scripting. Static code analysis tools can help identify potential flaws early.

In addition to that, regularly scan the codebase for known vulnerabilities using tools like vulnerability scanners and penetration testing. Patch identifies vulnerabilities promptly to minimize exploitation risks.

2. Data Encryption and Access Control Mechanisms:

Implement strong data encryption algorithms (AES-256) to protect sensitive data both at rest (stored) and in transit (transmitted). Utilize key management best practices to ensure proper key rotation and secure storage.

Implement granular access control based on the principle of least privilege. Moreover, implement role-based access control (RBAC) and attribute-based access control (ABAC) to restrict access to authorized users and specific data elements.

3. Robust Authentication and Authorization Procedures:

Employ Multi-Factor Authentication (MFA) to verify user identity beyond just passwords. Consider biometrics or hardware tokens for additional security.

Furthermore, clearly define user roles and permissions using a permission matrix. Regularly review and update access privileges based on user roles and job functions.

4. Risk Assessments and Penetration Testing Throughout Development:

Conduct regular risk assessments throughout the development lifecycle to identify potential security threats and vulnerabilities. Prioritize risks based on likelihood and impact.

Regularly engage ethical hackers to perform penetration testing to simulate real-world attacks and identify exploitable vulnerabilities. Address identified vulnerabilities before deployment.

Specific Considerations for Custom EHR Development:

Developing a custom EHR system requires careful planning and consideration of various factors to ensure its success, usability, and compliance with industry standards.

Here are some specific considerations for custom EHR development:

1. Data Integration and Interoperability

• EHR data needs to comply with standardized data formats like HL7 (Health Level Seven) or FHIR (Fast Healthcare Interoperability Resources) for seamless exchange between systems.

• Develop robust APIs and consider integration platforms to connect with labs, pharmacies, and other healthcare systems.

• Ensure smooth data migration between different systems and clean up inconsistent data formats.

2. User Access Privileges and Audit Trials:

• Assign access based on user roles and responsibilities to protect patient data.

• Maintain comprehensive audit trails of all user actions for security and compliance.

• Ensure the system adheres to HIPAA, GDPR, and other data privacy regulations.

3. Cloud-Based Storage and Mobile Health Applications:

• Ensure robust security measures and compliance with data protection regulations.

• Implement policies and solutions to protect data accessed through mobile devices. Ensure

• seamless data access and synchronization even with intermittent internet connectivity.

4. User Training and Ongoing Awareness

• Ensure users understand the EHR system’s functionality and best practices for data security and privacy.

• Minimize errors and maximize adoption of the new EHR system.

• Adapt to evolving regulations and security threats.

Best Practices and Recommendations

Developing a custom EHR demands meticulous attention to security and compliance.

Here are some best practices and recommendations to guide you:

For Developers

• Security by Design: Integrate security measures from the beginning, not as an afterthought. Follow secure coding practices and penetration testing methodologies.
• Compliance Expertise: Understand relevant regulations like HIPAA, HITECH, and GDPR. Seek legal counsel early and often.

• Data Encryption: Encrypt data at rest and in transit (e.g., AES-256). Use strong ciphers and key management protocols.

• Least Privilege Access: Implement role-based access controls (RBAC) and limit access to data on a need-to-know basis.

• Audit Logging and Monitoring: Track user activity and system events for potential breaches and suspicious behavior.

• Regular Patch Management: Apply security patches promptly to address vulnerabilities in your system and libraries.

• Secure API Design: Follow secure API design principles like OAuth 2.0 and OpenID Connect to protect data access.

For Healthcare organizations

• Risk Assessments: Conduct regular risk assessments to identify and mitigate potential security threats.

• Security Awareness Training: Provide ongoing security awareness training to all staff, including HIPAA training.

• Vendor Management: Ensure EHR vendors have robust security practices and conduct due diligence before selecting a vendor.

• Incident Response Plan: Have a documented plan for responding to security incidents quickly and effectively.

• Disaster Recovery and Business Continuity: Implement a plan to restore operations in case of a disaster or outage.

• Patient Engagement: Educate patients about their data rights and how their information is protected.

Frequently Asked Questions