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Security Maintenance Plan:

1. Introduction:

Dr. Joe Bob’s Family Practice is in need of an offsite security maintenance plan to maintain the highest level of security for patient medical files in case of an emergency, disaster, or critical intrusion on the network system. Techs Rx, Inc. has agreed with Dr. Joe Bob’s Family Practice, to put in place a security maintenance plan for Dr. Joe Bob’s Family Practice. This plan will involve an offsite data storage company by the name of First Choice Data Management, Inc.

The security maintenance plan will provide offsite storage of electronic medical records of all patients and include an onsite inspection by a representative of First Choice Data Management. The representative will inspect the health and condition of all critical files of the network, and perform the necessary operations to correct all deficiencies of the file system.

Tech Rx, Inc will be responsible for contacting First Choice Data Management, Inc. and setting up Dr. Joe Bob’s Family Practice with the first initial request to the offsite storage facility. This will be done only one time, and only for the first initial set up. After the first initial setup, a manager from Dr. Joe Bob’s Family Practice will be responsible for any transactions thereafter.

2. Budget/Cost:

Techs Rx, Inc. recommends that Dr. Joe Bob’s Family Practice contracts the services of a certified and technically competent IT consulting firm to maintain all critical business networks on a weekly or monthly basis, for firms that lack the time and technical staff to do this perform this task.

The cost/budget associated with the planning, implementation and installation shall be agreeable upon by Techs Rx, Inc. Dr. Joe Bob’s Family Practice. Any changes in costs that exceed the budgeted amount agreed upon must be agreed upon by Techs Rx, Inc. Dr. Joe Bob’s Family Practice.

The overall cost of the offsite back up service provided by First Choice Data Management, Inc. will be in the amount of $290.50/per month and will service 4 servers with 100GB of storage space for all files, including all patient medical records.

First Choice Data Management, Inc. is the facility that will be handling all services pertaining to data back-ups and storage for Dr. Joe Bob’s Family Practice.

3. Performance measures:

Techs Rx, Inc. understands the key systems listed as follows:

Files and print services, Internet and email systems, Backup business software, Virus protection and firewalls will be inspected and updated accordingly to the latest service packs and/or revision during the regular maintenance visits by Techs Rx, Inc.

Techs Rx, Inc. agrees that upon completion of required work, our skilled and experienced technicians will complete a job sheet; outlining the date, time, and a brief description of all work carried out. Our technicians will also complete a customized checklist and supply Dr. Joe Bob’s Family Practice with a final report on the current status of all networks on the system.

The task list to be carried out will include the following:

Review server error logs and address any issues that might cause a problem.

Apply any critical service packs and software upgrades.

Check capacity of hard disk drives and monitor disk usage.

Verify that the backup procedures are working properly and conduct a test restore to a folder. This will verify that the tape drive is operating properly.

Check internet/email servers and review error logs and carry out periodic cleaning of queues.

Upgrade firmware in firewalls and verify they are operating properly.

Test speed of network and internet connection via sample download/upload.

Ensure that virus updates are being applied automatically and review virus activity logs.

Address all miscellaneous workstation related issues that did not warrant a specific visit.

Meet with Dr. Joe Bob’s Family Practice employees responsible for the security/maintenance and discuss current issues and address future requirements needed for the network system.


A customized task list will be created to suit each individual environment to ensure that key areas are being addressed. Estimates for regularly scheduled maintenance can range from several hours/month to more than 8hours/week, depending on the size and complexity of the network. This estimate excludes any time spent addressing miscellaneous server and work station issues not listed on the checklist. Scheduled maintenance is normally used in conjunction with a priority support contract to apply significant cost savings.

4. Business Owner Management /Security:

Techs Rx, Inc. will provide remote monitoring for Dr. Joe Bob’s Family Practice will be available 24 hours a day 7 days a week. If the network at the practice should become unoperational for any reason, an email alert will be sent immediately; detailing the error and contact your IT provider to rectify the situation immediately.

Techs Rx, Inc. will also provide access to our support channels via email, omline tech support chat, and telephone

5. Documentation Strategies:

The HIPPA has a policy and procedure documentation mandate that states that a practice must implement reasonable policies and procedures to comply with the standard implementation specification and other requirements of the security rule.

The documentation policy is as follows:

Policies and procedures to prevent, detect, contain and correct security violations.

Sanction policy

Procedures to regularly review records od information system activity.

Policies and procedures to ensure that all members of a covered entity’s workstation have appropriate acces to patient medical records.

Procedures for authorization and/or supervision of workstations members who work with patient medical records or are in the location where it is accessed.

Procedures to determine that access of workstations to patient medical records and for terminating access to patient medical records when employment of a worker ends or is terminated.

Policies and procedures for authorizing access to patient medical records.

Policies and procedures to isolate a healthcare function from unauthorized access by a larger organization.

Policies and procedures for granting access to patient medical records and to establish document review and modify a user’s right of access.

Policies and procedures to responding to an emergency or other occurrence that damages patient medical record contingency plans.

Data backup plan to create and maintain retrievable copies of patient medical records.

Disaster recovery plan to restore any loss of data.

Emergency mode operation plan to enable continuation of critical business process for protection of the security of patient medical records, while operating in emergency mode.

Procedures for periodic testing and revision of contingency plans.

Policies and procedures to identify and respond to suspected or known security incidents.

Procedures to migrate to the extent practicable known harmful effects from incident.

Documentation will of security incidents and their outcome.

Documentation will be in written or electronic form.

Retaining the documentation for (6) six years from the date of its creation or from the date of revision or date when last was in effect, whichever is later.

Making documentation available to persons responsible for implementing the procedures, plans and reviewing the documentation periodically and updating documents as needed.

6. Security:

The HIPPA privacy and security rules require a practice to take any appropriate and reasonable measures to ensure and safeguard the individual’s patient medical records. There are administrative, physical and technical safeguards in both rules.

The administrative safeguards within the security rule are administrative action policies, procedures and plans related to the selection, development, implementation and maintenance of security measures.

The first administrative security standard requires a practice to create, administer and oversee a security management process (i.e. policies and procedures.) to prevent, detect, contain and correct security violations. The security administrative standard is the backbone of the foundation of all HIPPA security and the final HIPPA security rule.

The security management process has four implementation specifications and are as follows:

1. Risk analysis and assignment. 2. Risk management. 3. Sanction Policy 4. Information System Activity review. A practice must access its technology including:
Application systems
Network infrastructure
Operating systems
Intrusion detection
Firewalls and anti-virus software

A practice must access its physical environment and people, including:
Bulletin boards
Cleaning personnel and other similar work staff
Visitors and patients
Computer screens
Copy machines
Fax machines
Desktops and countertops
Disposal of paper
Medical record storage and transcriptions

A practice must consider all of its assets/resources including:
IP/web servers
Heating/Air conditioning
Miscellaneous supplies
Couriers and U.S. Mail

A practice must consider its special conditions including:
Type of service provided and type of governance (business structure or model)
Security provided for Dr. Joe Bob’s Family Practice will include the following:
A hardware/software assessment which includes all servers on the network, Entire network including:
Communication servers
Bandwidth connectivity and storage
All databases with patient medical records
All computers connected to the network system for data processing and analysis

System inventory should include the following:
All policies/procedures that impact security of patient medical records
All information systems with a focus on critical sensitive patient medical records processed by these systems
Business associates and employees and how they process and use patient medical record
Biomedical equipment that contains patient medical records
All employees that have remote access of any kind to patient medical records and all vendor partners who also have access to patient medical records.

6.1 Password management is as follows:
Users must maintain the confidentiality of user accounts and passwords. Furthermore, passwords used to access external services must not be identical to any password used on an internal corporate system. User account IDs and passwords transmitted over external services, such as the Internet, may be transmitted in clear text and are easily susceptible to discovery. Strong passwords must be used on the external perimeter network.
Some guidelines for password use are: * Passwords must contain at least eight characters, and preferably nine (recent security information reports that many cracking programs are using the eight character standard as a starting point). Also, each password must follow the standards set for strong passwords. * All passwords used by the built-in Windows 2007 accounts (including service accounts) must be changed to conform to the password standard. * It is mandatory that all accounts have passwords. No blank passwords are permitted. * Never loan your password out. If for some reason you must share your password, remember to change it immediately. * Passwords must be changed every 30 days. The system will keep a history of the last six passwords used and not allow repeats. This forces users to use at least seven unique passwords. * Never write your password or send it via e-mail. * Accounts will be locked out after three bad password attempts (administrators should set lockout duration to more than 30 minutes or until an administrator unlocks the account).
6.1.1. Unacceptable Usage:
Dr. Joe Bob’s Family Practice external services usage policy is as follows:
The practice characterizes as unethical and unacceptable any activity that purposely: * Seeks to use Dr. Joe Bob’s Family Practices’ services for private or personal business. * Seeks to gain unauthorized access to any resources within or outside of the practice. * Disrupts the intended use of the practice and/or the perimeter network services. * Wastes resources (people, capacity, and computer) through such actions. * Destroys the integrity of or misuses any information assets. * Compromises the privacy of any user or other departments. * Compromises proprietary or otherwise sensitive patient information. * Places material on any perimeter network platform that would be considered inappropriate, offensive, or disrespectful to others.
Dr.Joe Bob’s Family Practice reserves the right to monitor any and/or all external perimeter network service-related activity. Any users found in violation of the above External Services Usage Policy may be subject to penalties. These could range from denial of access, at a minimum, to termination of employment and/or criminal prosecution.

6.1.2 Restrictions on Posting or Downloading Copyrighted Materials
All users are required to comply with copyright and software licensing agreements. It is explicitly against the Corporate Information Security Policy to violate such agreements. Uploading or downloading copyright protected material is expressly prohibited. Displaying or posting copyrighted material on any intranet or Internet server (servers placed in the perimeter network) is expressly prohibited.
6.2.Reporting Security Problems
Any suspicious activity or suspected security compromises to the perimeter network must be reported to the information security department.
6.2.1. Virus Precautions
All information downloaded from external services or posted to the perimeter network must be immediately scanned for viruses using the corporate approved virus-scanning software.
6.2.2. Terminating External Session not Actively in Use
If you are not actively using a session, it will be disconnected. A timeout procedure for all idle connections to the perimeter network is in place.
7. Sanction Policy
Techs Rx, Inc. will develop and layout a progressive escalation of penalties and create an enforcement escalation process that includes executive management sign off for the most gregarious behaviors and willful actions. Finally, it is suggested that all employees sign off on the new sanction policy, penalties and the escalations process so they know that HIPPA makes everyone who works with patients medical records responsible for keeping it secure and private.
Dr. Joe Bob’s Family Practice will need to determine the following as the escalation process is developed:
When is it appropriate to make the first call-the level of intrusion or improper release of patient medical records.
Whom to call first- Name the role not the individual and when to call (time frame)
What is the escalation trigger time and are there any escalation events for the next level or time elapsed.…...

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