As the Covered Entity your company has the responsibility to protect its PACS system (Exa server) and all interconnecting networks that house PHI data. Please ensure that your organization has the appropriate physical security and cybersecurity deployed to safeguard your PHI data from breach or ransomware. These measures should be aligned to your organizations risk acceptance and privacy rule standards, under the HIPAA regulatory requirements, from the Department of Health and Human Services (“HHS”).
These safeguards include but are not limited to:
- Reasonable perimeter security (area access restrictions)
- Appropriate network segmentation
- Multiple firewalls and routers
- Data encryption at any points of PHI. “at rest” and “in transit”
- Appropriate endpoint protection. AV/Malware protection, Endpoint Detection and Response EDR
- An appropriate Disaster Recovery and Business Continuity (DRBC) plan that is tested regularly to ensure it will work properly in the event of ransomware attack or system failure
At no time should you have port 104 (or any other port) open directly to the internet without a robust and up-to-date VPN that uses 256 AES data encryption.