When was the last time that you reviewed your access logs in your healthcare practice?
In our policies, procedures, risk assessments, and privacy impact assessment submissions, we indicate the reasonable safeguards that we expect to implement in our practices to protect the privacy and security of health information.
But policies and good intentions alone isn’t enough.
We also need to take action on our policies.
We have tools, like audit logs, available to us. Audit logs of our computer and software systems are available to monitor users who have accessed the system and the information contained in the systems.
Audit logs monitor and records the transactions of users’ activities in your computer network and your electronic medical record (EMR). It is an automated, real-time recording of who did what, and when, in your system.
For example, when a user logs in to your computer network at the beginning of the work day, the user name, date, time, and perhaps the workstation identifier is recorded in the audit log.
When the user logs into the EMR and creates, views, modifies, or prints from a specific patient record, each activity is recorded in the audit log. In this way, the audit log records both the activity of each user and, in each patient’s electronic medical record, who has accessed that patient’s health information.
You MUST implement, use, and monitor your audit logs
The regular review of the audit logs can demonstrate that the administrative, technical, and physical safeguards that we implement to protect the health information, our people, and our assets are working. Review of audit logs can also identify weaknesses so that corrective action can be taken to improve our privacy and security strategy.
For example, when you review your audit log, you may see that an employee (authorized user) is accessing the EMR after clinic hours. When you investigate, you find out that the billing clerk is doing the billing submission from home.
This might be OK in your healthcare practice (or not). But, now you know what is happening iin your clinic EMR after hours and you can take appropriate action.
Audit Logs Are Valuable Metadata
Taken from a different point of view, the audit log provides important additional information, or metadata, about the care and treatment of the patient. Knowing who created a clinic note, wrote a prescription, or reviewed a test result provides a story about the care that the patient received. For this reason, the audit log of the EMR is usually required by legislation to be maintained for the entire retention period of the patient’s record. This is generally 10 or more years for adult patients and longer if the patient was a child at the time that they were a patient or client in your practice.
How You Can Use Audit Logs to Improve the Security of Health Information In Your Practice
Snooping, or viewing someone’s health information for an unauthorized use, is not uncommon in healthcare. Snooping is always a breach of confidentiality and trust that our patients give to us.
Sometimes, snooping is because someone is concerned or curious about a family member or friend and don’t intend to do anything ‘bad’ with that information.
We also know that people will sometimes access information for malicious means – that is, using a ‘criminal intent’ or to be mean or disparaging to the individuals involved.
When you regularly review your audit logs, you
- Create a deterrent to all users to check something out ‘just this once, no one will know’.
- Find potential threats or weaknesses in your current systems that you can improve to better mitigate your risks.
Custodians have an obligation to ensure reasonable safeguards to protect the privacy and security of health information. This means having appropriate policies and procedures in place and demonstrate and document that you have implemented your plans.
Action Steps That You Should Do Now
Use these points as a checklist to help you start using your audit logs to improve security in your healthcare practice.
- Computer Network System Audit Log
- Ensure that your computer network system has audit logging enabled.
- Access and review your audit log. Don’t skip this step! Don’t assume that your audit logging is properly set up. You must discover how to access the audit log and record the procedure so that you can quickly access the audit log in the event that you have a privacy and security breach or routine security audit.
- Determine how long your audit log information is accessible or retained. Is it included in your routine backup files? Legislative retention requirements differ but you probably want to keep the audit logs accessible for six months or longer.
- Can you automate an audit log reporting tool to make it easier to review your audit logs regularly? Who in your healthcare practice is responsible to do this?
- Electronic Medical Records (EMR) / Electronic Health Records (EHR) System Audit Log
Click the link below to get your copy of the audit templates and the training video!
