If you’re looking for the short answer to the question, “Is HIPAA compliance possible in the public cloud?" the answer is “Absolutely, yes!” But let’s be honest — there are no short answers to anything involving HIPAA compliance.
One reason is that HIPAA regulations are purposely written in generic language to apply to a wide variety of people and organizations that handle Protected Health Information (PHI).
Another reason is that many leaders are looking for a platform to make their organizations HIPAA compliant as part of their digital transformation.
Unfortunately, there isn’t a platform on the planet that can implement the internal processes necessary to pass HIPAA regulations for you.
But, with a combination of a robust cloud-based platform, a Document Management System (DMS), and clear internal processes, you can have peace of mind and worry less about sustaining HIPAA compliance for your organization.
What’s so special about the public cloud?
Organizations interested in digital transformation have the option of moving to a public cloud, a private cloud, or a hybrid cloud solution.
While there are advantages to all three options, the public cloud offers organizations a cost-effective infrastructure that’s:
- More agile
- Easier to set up
- Requires no maintenance from the organization
- Offers tremendous economies at scale that private and hybrid clouds are hard-pressed to match
However, many organizational leaders question the integrity of something they can’t control. In general, humans have a hard time letting go of the wheel and taking a back seat.
With that loss of control, it’s only natural for us to question how reliable a solution is, especially when dealing with strict compliance rules and regulations, like those of HIPAA. When we’re in control, we feel safer — whether we truly are or not.
How secure is the Public Cloud?
Contrary to popular belief, the public cloud is actually more secure than private internal networks. And when it comes to HIPAA compliance, at the minimum, public cloud-based platforms must adhere to the following three rules per the signed Business Associates Agreement (BAA) between a covered entity* and a business associate**:
Quick vocabulary lesson: A covered entity* is any healthcare provider, health plan, or health care clearinghouse that regularly handles PHI (like a hospital).
A business associate** is any person or organization that provides a service to a covered entity in which they would have to access PHI (like a cloud platform). The business associate signs the BAA, promising to uphold HIPAA compliance standards.
Both the covered entity and business associate must meet all three HIPAA rules on their own. Let’s take a quick look at the Security Rule, which has three standards that both parties must abide by to be HIPAA compliant: physical, technical, and administrative.
Required physical standards, for example, include restricting facility access and creating policies around the governance of PHI on mobile devices — anything that involves the “physical” security of information.
Such physical standards must also be adhered to by the cloud-platform provider, or the “business associate.”
A perfect example of this is the Google Cloud Platform (GCP). I’m going to go out on a limb and say that Google’s secure data centers are more secure than the average hospital. Protecting data is what they do, and they do it well — arguably unmatched. Because of this level of security, you know that your underlying infrastructure is secure.
Also, using a public cloud platform helps organizations fulfill a slew of other HIPAA compliance requirements, such as:
- Two-step authentication
- Back-up and disaster recovery
- Threat protection
Another benefit of opting for the public cloud when having to meet HIPAA compliance requirements is the number of tools and apps available to further strengthen adherence, like a strong document management system (DMS).
HIPAA Compliance and Document Management Systems
As a healthcare organization, or any other agency handling PHI, your HIPAA compliance requirements revolve around not only protecting files but also being able to show the details of file lifecycles. Did someone say “audit”?
Most health organizations are coming from rigid legacy systems and, in the past, solely depended on data loss prevention capabilities and admin oversight to protect patient files. It’s a recipe for costly disasters, which is why the combination of modern cloud-computing technology and DMS is a breath of fresh air compared to the usual, outdated protocol.
Records Management, Retention, and Disposal
Per HIPAA requirements, health organizations must retain patient documentation for at least six years from when it was created or when it was last in effect.
Not only can you define retention rules and use custom metadata to set retention start dates, but with DMS software, you can also set disposal rules during customization, so documents can either be deleted automatically or manually. Also, admins with permission can review files before deletion and receive audit reports about disposals.
Centralized ownership of files is critical to maintaining HIPAA compliance standards. DMS software gives organizations the power to decide levels of access depending on roles, titles, and other forms of permissions.
It also prevents unauthorized users from gaining access to private files, or sharing them, and protects sensitive records from being modified or deleted — properly securing the environment that maintains PHI files.
Yes, someone said “audit.” When an audit rolls around, your documents and patient files have to act as detailed maps, being as transparent as possible, showing the who, what, when, where, and whys of all activity.
If negligence, noncompliance, or even fraud are anywhere in the vicinity of PHI files, you and your organization have to act as quickly as possible — and know as much as possible.
While the public cloud can provide a secure infrastructure, smart DMS software is crucial to help you manage the processes and procedures necessary for HIPAA compliance when maintaining a secure environment for PHI files. It’s a match made in compliance heaven.
We’ve only scratched the surface of what’s possible with the public cloud and the beneficial tools it can offer in your quest for HIPAA compliance.
And remember — at the risk of sounding like a broken record — it’s imperative to note that the responsibility of HIPAA compliance rests on the shoulders of your organization’s internal processes and administration.
If you’re considering migrating to the Google Cloud Platform, or are in the middle of a migration, we’re always available to talk about your options and how a DMS, or an enterprise-level Content Management System (CMS), can help you scale efficiency in the most cost-effective way possible. Contact us or try us out for free to see how easy securing your documents and streamlining business-critical processes can be.