As we see the advent of Healthtech, a question that every entrepreneur has in mind while building the platform is whether it is HIPAA compliant or not. While we do recommend to have your software audited for compliance by an expert, here are some of the things that you can get done when you use AWS as a backend for any healthcare app.
To increase operational efficiency a lot of businesses are using cloud providers like Amazon Web Services to manage their IT infrastructure. A huge number of healthcare providers today use AWS cloud to store, process, and send protected health information (PHI) under HIPAA regulations.
AWS has a secure environment for the maintenance and retention of sensitive health information under the Health Insurance Portability and Accountability Act (HIPAA). To start using AWS HIPAA-compliant cloud storage, a healthcare company must sign a Business Associate Agreement (BAA) with AWS. It covers the security, control, and administrative processes mentioned in HIPAA.
AWS offers an extensive AWS HIPAA services list to develop scalable, secure, and fault-tolerant HIPAA solutions that can serve an unlimited number of healthcare use cases.
It’s very important to understand HIPAA compliance and things that can go wrong if we don’t follow it properly. Here is the list of fines/penalties imposed by authorities, one can see how much serious damage it can make to your business if you don’t build your software correctly.
Major components of a 3 tier architecture of any software are Client interface, Web or Mobile app, Server interface, APIs, and Database which stores the data. When it comes to HIPAA we have to make sure that all these 3 tiers are secured following all best practices and guidelines provided by HIPAA.
As far as operational and physical security is concerned, AWS has multiple layers to provide the integrity and safety of customer data. But just using AWS services doesn’t ensure HIPAA compliance of your solution. When your AWS-based system deals with ePHI, you must follow the AWS HIPAA technical requirements and regulations.
The AWS HIPAA compliance efficiency is dependent on how it is used. AWS helps to build high-load systems that process vast amounts of ePHI under HIPAA. But, AWS only assumes responsibility for physical hardware security controls of a limited number of covered services listed here.
AWS has a shared responsibility model to increase the total security level of Amazon’s cloud infrastructure.
Amazon handles managing infrastructure components and the physical security of the AWS data centers at different geographic locations. The AWS customers are responsible for the security and HIPAA-compliant architecture of cloud services that are being used. Let’s discuss the shared responsibility model in a more detailed manner. Here is a quick glance into the shared responsibility of Amazon and the Customer.
Amazon is in charge of the physical security of AWS cloud infrastructure. They manage the following areas:
Customers are responsible for the security of AWS services being used and configured according to HIPAA-compliance solutions. Customers manage the security of the following areas
Access control plays an important part of any system, it is cloud-agnostic. As per HIPAA guideline, our application should ensure that only authenticated users will be able to access the resources which are granted for them. AWS has a great service called IAM – Identity and Access Management which helps us to grant specific access to specific users in easy steps.
IAM enables you to manage access to AWS services and resources securely. With its help, you can create and manage AWS users and groups, and use permissions to allow and deny their access to AWS resources.
Each account owner on AWS has the ability to install and configure retention for all services he uses, to prevent unnecessary data from being stored as well also to delete data from the service upon request, the application should give users a way to delete the data. Any company that collects health information must ensure it’s properly destroyed.
HIPAA requires that media has been cleared, purged, or destroyed consistent with NIST Special Publication 800-88, Guidelines for Media Sanitization, such that the PHI cannot be retrieved.
AWS Backup is a managed solution for automatic backup application data for all AWS services. It is a faster and easier backup solution for AWS customers. In the old era backup and recovery was a nightmare but AWS has made it pretty easy. It can be set up on a regular basis or carried out on request.
It also monitors the status of current backups, searches/restores backups to ensure compliance with corporate and regulatory requirements. Most AWS services like RDS, Elasticache, S3 have native backup functionality.
To ensure data integrity AWS offers a very robust security feature for encrypting the data stored in different services. Amazon S3 is used for object storage and has great data encryption options. Each S3 object is encrypted with a unique key that is encrypted and rotated on a regular basis. Amazon S3 uses the strongest block cipher available – 256-bit Advanced Encryption Standard (AES-256).
As far as other services are concerned, to encrypt PHI data, Amazon offers KMS service which is a HIPAA compliant solution for managing encryption keys with other AWS services. KSM has a concept of Master keys that can be used to encrypt/decrypt the keys used for encrypting/decrypting the PHI data inside the application.
AWS has given an easy way to encrypt an RDS database or your block storage devices like EBS with few button clicks. The rest of the things are taken care of by AWS. For security in transit, we can use SSL layer in order to encrypt all network traffic, AWS also offers a service called certificate manager to manage all your SSL certificates at free of cost.
To achieve network-level security, it is best practice to separate out the PHI data VPC with other non-phi data VPC, though it’s not compulsory, most large organisations follow it. The following diagram shows a standard architecture on AWS for HIPAA security.
Auditing and Monitoring is an essential part of HIPAA compliance. Amazon introduced AWS Config for the same purpose. It is a fully managed service that provides you with AWS resource inventory, configuration history, and configuration change notifications to enable security and governance.
AWS Config allows discovering existing and deleted resources, compliance against rules. The solution simplifies auditing, security analysis, change management, and operational troubleshooting.
HIPAA rules require covered entities to track login attempts and report errors. CloudTrail provides an event history of your AWS account activity. It helps to identify log entries related to sign-ins, including the IP address and Multi-Factor authentication. CloudTrail also determines successful sign-ins by users in IAM and root. These features allow customers to simplify operational analysis and troubleshooting.
It’s really important to implement inactivity session logouts as per HIPAA guidelines. Using REST APIs along with frontend and backend combination, one can easily implement the same. Though there is no global standard for timeout duration, It is important to understand that the risk of an “open” connection on an unattended workstation largely depends on the physical surroundings.
On an open floor in a hospital or in a busy emergency room accessible to the public, the risk is high and the timeout should be shorter than 15 minutes.
AWS provides everything to set up a HIPAA compliant telehealth platform. But, you still need to follow HIPAA security rules, maintain data confidentiality, and follow industry best practices for data protection. As mentioned in the shared responsibility part, both parties are equally responsible for HIPAA compliance.