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Improve Your Healthcare Practice Security With Audit Logs

Posted on March 15, 2023 by Jean Eaton in Blog

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How to Improve Your Healthcare Practice Security With Audit Logs

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 Log Image

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.

Say No to Snooping

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
    • Most health information legislation and regulations now require EMR / EHR to include an integrated audit log / access log. Confirm that you have enabled your EMR / EHR audit log.
    • 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 as long as you retain the entire patient record – generally, 10 or more years years.
    • 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? Check out the Practice Management Nuggets Podcast

      How AI Improves EMR Auditing | Episode #094 with Rob Pruter from SPHER.

    • User activity recorded in an audit log is often visible to subsequent EMR users when they access a patient record. In the course of routine workflow, users may observe and question inappropriate access to an individual patient record. Instruct your users to notify the clinic manager or privacy officer if the audit log indicates a suspicious activity.
    • Include the review of audit logs as part of your routine privacy and security monthly audit.

Click the link below to get your copy of the audit templates and the training video!

I Want the Audit Templates to Improve Privacy and Security!

Are you already a member of Practice Management Success?

The instructional video and Privacy and Security Monthly Audit Template is already in your membership!

Click the button now to go to the membership to access your resources.

Go to my Practice Management Success membership

 When we know better, we can do better…

Jean Eaton is constructively obsessive about privacy, confidentiality, and security especially when it comes to the handling of personal health information. If you would like to discuss how I can help your practice, just send me an email. I am here to help you.

Jean L. Eaton
Your Practical Privacy Coach
INFORMATION MANAGERS

audit log, EMR, health care, healthcare practice, medical, reasonable safeguards

Merging Your Healthcare Practice – PIA Considerations

Posted on August 3, 2020 by Meghan in Blog

Merging Your Healthcare Practice – PIA Considerations

 

Mergers and acquisitions and closing and consolidating are activities that healthcare practices undertake at various times in the life cycle of a business.

There are many reasons why a practice may consider buying or acquiring an existing healthcare practice.

You might be expanding your practice to rapidly expand the scope of your services, location, or space. Or you might be downsizing your practice. Or maybe you're merging multiple practices into one streamlined practice so you can better manage your profit margins.

You might be looking to diversify your services or, perhaps, create an area of super-specialty that will provide a competitive advantage for your healthcare practice.

You might be wanting to acquire skilled employees or healthcare providers that you couldn't recruit in your current circumstances.

You might be acquiring or consolidating real estate infrastructure, medical equipment or electronic medical records, computer networking, or perhaps the management team. Or you might be exploring opportunities for economies of scale or cost-cutting.

As a custodian (including physicians, pharmacists, dentists, chiropractors, nurse practitioners, optometrists, and more) you need to ensure that the patient's health information remains private and secure, and that patients have continued access to their health information.

 

Thinking about merging your healthcare practice? Important privacy impact assessment steps for you to consider. #PIA #Privacy #ProtectYourPractice Click to Tweet

5 Important Steps Before You Merge Or Close Your Healthcare Practice To Ensure Your Continued Privacy Compliance

  1. Inventory All Your Existing Patient Records
  2. Patient Records Systems
  3. Agreements
  4. Existing Documents
  5. Privacy Impact Assessment Amendment Plan

 

Read the full article below!

Or listen to the podcast here

Inventory All Your Existing Patient Records

 

When you assume a new practice, you need to know where all the patient records are maintained. If you are closing your practice, you need to ensure the continued security and access of patient records to the patient.

To do this, you need to know which patient records are included in the practice. Create an inventory of the existing patient records.

Remember that you must meet the records retention period (which often is 10 years plus the age of majority) for all the patient records. Make sure that you are meeting the records retention periods and that you have correctly inventoried all of the patient records. This includes all locations and record types including paper, off-site storage, and records that have been backed up to an electronic drive or a separate memory device.

Include all types of patient records – including appointment records, appointment books or electronic scheduling software, billing records, paper records, diagnostic medical devices, electronic medical records and audit logs.

When you assume a new practice, you need to know where all the patient records are maintained.

Patient Records Systems

 

Make sure that you review all the existing patient record systems – electronic medical record, billing systems, records storage, etc. – and the associated termination clauses with the vendors. If you need to transfer the management of patient records between custodians or to a different system, you need to thoroughly explore the data migration and archiving options and the associated costs.

Remember, you must maintain the complete patient record – including the clinic notes, test results reporting, task management, internal messaging, and audit logs – for the entire retention period. Often, exporting a patient record to a PDF file format does not include the complete patient record. Instead, you may need to maintain a read-only version of the electronic medical record.

Agreements

 

Collect all the existing agreements between the custodians and the vendors and stakeholders with whom the custodian has authorized the collection, use, and disclosure of patients’ health information. This may include the EMR vendor, billing agent, custodians, Primary Care Network, and successor custodian agreements.

Existing Documents

 

Request a copy of the existing documents that support the business of managing the patient records, including the health information privacy and security policies and procedures and privacy impact assessments. This will help you to respond to inquiries about previous patient records management practices and assist you in preparing your next privacy impact assessment.

Privacy Impact Assessment Plan

 

Consider the history of the current practices and plan your new operations plan. Complete a risk assessment to ensure the appropriate reasonable safeguards of previous, current, and future patient health information. Then, complete a Privacy Impact Assessment and update the Health Information Management Privacy and Security Policies and Procedures. In Alberta, the Health Information Act (HIA) requires the custodian(s) to submit the Privacy Impact Assessment to the Office of the Information and Privacy Commissioner (OIPC) for review prior to implementing new practices.

 

If you want to know more about Privacy Impact Assessments with step by step instruction, training, and mentoring, register for the on-line training, Protect Your Practice, Your Assets, and Your Patients with Privacy Impact Assessments. 

Related Resources

Watch these Practice Management Nuggets For Your Healthcare Practice Videos:

  •  When You Close Your Healthcare Practice on YouTube
  • What to Consider Before Sub-Leasing on YouTube

Download:

  • Top 3 Agreements Your Healthcare Practice MUST Have (and Why)
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