Our review found that ONC had application information technology (IT) security controls in the interoperability specifications, but there were no HIT standards that included general information IT security controls. General IT security controls are the structure, policies, and procedures that apply to an entity's overall computer operations, ensure the proper operation of information systems, and create a secure environment for application systems and controls. At the time of our initial audit, the interoperability specifications were the ONC HIT standards and included security features necessary for securely passing data between EHR systems (e.g., encrypting transmissions between EHR systems). These controls in the EHR systems were application security controls, not general IT security controls.
We found a lack of general IT security controls during prior audits at Medicare contractors, State Medicaid agencies, and hospitals. Those vulnerabilities, combined with our findings in this audit, raise concern about the effectiveness of IT security for HIT if general IT security controls are not addressed.
We recommended that ONC (1) broaden its focus from interoperability specifications to also include well-developed general IT security controls for supporting systems, networks, and infrastructures; (2) use its leadership role to provide guidance to the health industry on established general IT security standards and IT industry security best practices; (3) emphasize to the medical community the importance of general IT security; and (4) coordinate its work with the Centers for Medicare & Medicaid Services and the Department's Office for Civil Rights to add general IT security controls where applicable. ONC concurred with our recommendations.Both reports are available with the following titles:
- Nationwide Rollup Review of the Centers for Medicare & Medicaid Services Health Insurance Portability and Accountability Act of 1996 Oversight
- Audit of Information Technology Security Included in Health Information Technology Standards