Does HIPAA have any effect on internal e-mails behind a firewall, i.e. will internal e-mails need to be encrypted?...
Also, what strength of encryption is needed externally, as well as any other requirements such as authentication, etc.?
Lastly, what exactly is considered confidential (clent ID/number, name)?
The HIPAA Security Rule, in its current proposed form, does not require internal e-mails on a wired network to be encrypted. E-mails are required to be encrypted if they go across an "open network" such as the Internet or even a wireless LAN. As of now, there is no minimum requirement for encryption strength. A common encryption strength is 168-bit (3DES), but 128-bit will usually suffice. Anything more may be overkill, anything less has been proven to be easily crackable. See Expert deconstructs the cracking of 64-bit key for more information on this subject.
Regarding authentication, the following is required:
- data authentication -- mechanism that provides proof that data has not been altered or destroyed in an unauthorized manner
- entity authentication -- mechanism that provides proof that an entity is who it claims to be
- message authentication -- mechanism to ensure that a message received matches the message sent
Most, if not all, of these requirements can be met with third party mail gateway products and authentication systems from various vendors.
Regarding what is considered confidential, it basically boils down to any individually identifiable health information including SSN, name, address, medical record numbers, treatment history, etc. -- anything that can be used to indentify a patient. Stay tuned, however, the HIPAA Security Rule may be finalized at the end of December 2002 and might contain updates or changes to this information.
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