HITRUST CSF and HIPAA assessments both aim to safeguard healthcare information and electronic Protected Health Information EPHI. However, both standards offer a different approach for organizations.
HIPAA was originally meant to be utilized for a wide range of organizations, resulting in a vague and subjective list of requirements to be HIPAA compliant. The HIPAA Security Rule allows for certain specifications to be only “addressable” while others are “required.” There is no official designation of HIPAA compliance.
HITRUST CSF assessments and certifications are organized around the specific risk of a certain organization. HITRUST CSF assessments also allow for a comprehensive approach toward information security as it considers compliance with other regulations. A HITRUST CSF assessment is an efficient and risk-based approach to information security because it draws upon existing frameworks, standards, and current regulations.
I.S. Partners, LLC will perform a HITRUST CSF readiness, certification, and remediation services for healthcare organizations and their business associates to assess compliance with industry security requirements and standards, and create solutions that help organizations align with the HITRUST CSF. If your company requires both a HITRUST CSF Certification and a SOC 2 report, I.S. Partners can leverage the efficiencies between both sets of requirements, thus lowering the time and expense of effective risk management.
A SOC 2 is a reporting format, while the HITRUST CSF is a security framework. A SOC 2 examination examines the internal controls at a service organization as they relate to one or more of the Trust Services Principles of Security, Availability, Confidentiality, Processing Integrity and Privacy. The SOC 2 reporting model and the HITRUST security framework are complementary since both are facilitated through the efficient assessment and implementation of controls to satisfy the HITRUST CSF.
An organization that creates, accesses, stores or exchanges Protected Health Information (“PHI”) can use its HITRUST CSF Certification to demonstrate that they meet the high standards of security prescribed within the HITRUST CSF. Many companies now accept a HITRUST Certification as evidence of compliance, thus relieving them of the obligation to audit their vendors. Companies such as Highmark, Humana, United Health Group, HCSC and Anthem now require their vendors to undergo a HITRUST CSF assessment. The HITRUST CSF incorporates all major information security-related requirements and best practices, and provides scalable cyber security measures based on different risks and exposures.
HITRUST is a privately held corporation in the United States that has established the HITRUST CSF to be used by organizations that create, access, store or exchange sensitive information. In collaboration with public and private healthcare technology, privacy and information security leaders, HITRUST has become the leader in safeguarding health information systems and exchanges.
1. A HITRUST CSF Self-Assessment allows an organization to conduct a review and assessment of its internal control environment using the standard methodology, requirements, and tools provided under the HITRUST CSF Assurance Program. The self-assessment option removes any potential barriers for organizations that lack the resources for an onsite assessment, but nonetheless must still implement data protection controls, maintain HIPAA/HITECH compliance, and report to external parties.
2. A HITRUST Validated Assessment is conducted by a HITRUST approved CSF Assessor, such as I.S. Partners, LLC. Using the HITRUST CSF Assurance methodology, an organization’s internal controls are scored accordingly. Assessments meeting or exceeding the current HITRUST CSF Assurance scoring requirements for certification will be indicated as “HITRUST CSF Certified” on the certification report from HITRUST.
The HITRUST CSF includes and embodies requirements from various authoritative sources such as ISO, NIST, PCI DSS, HIPAA and others, and tailors the requirements to healthcare organizations based on specific organizational, system and regulatory risk factors. The level of integration and prescription in the framework, along with the quality and rigor of the HITRUST CSF Assurance Program and supporting HITRUST products and services, makes the HITRUST CSF the easy choice for healthcare organizations.
HITRUST and the American Institute of Certified Public Accountants (AICPA) have joined together to map HITRUST CSF controls to the Service Organization Controls (SOC) 2 Trust Principles and Criteria, specifically the Trust Services Principles of Security, Confidentiality and Availability. I.S. Partners, LLC, as both a CPA firm and a HITRUST CSF Assessor, can perform a SOC 2 audit leveraging the HITRUST CSF framework. If an organization requires both a SOC 2 and a HITRUST CSF Certification report, the two reports can be combined into a singular report.
Given the positive fulfillment of the interim review requirement, where no breach has occurred and no significant changes have developed relating to the scoped control environment, HITRUST CSF reports with Certification are valid for two years. However, at the one-year anniversary of the Certification, I.S. Partners, LLC can perform your organization’s interim review by:
- Requesting your organization to update the scoping questions
- Reviewing the updated questionnaire for any changes to original questionnaire
- Testing at least one control/statement in each domain
- Reviewing the status of any Corrective Action Plan (CAP) from the original assessment to ensure that satisfactory progress/milestones are being met
No single vendor or product will cover all 12 PCI-DSS requirements or meet several minimal standards. Instead, you should create a comprehensive security strategy that reaches PCI compliance and then use products and vendors that further complement your network system security to provide enhanced protection.
If you decide to outsource your credit card transactions, you will still need to meet PCI-DSS compliance when transmitting cardholder data to the outsourced company. You also need to ensure that the outsourcing company you use meets PCI-DSS compliance.
Any business or merchant that accepts credit card payments, transmits cardholder data, processes transactions and/or stores cardholder information falls under PCI-DSS requirements.
No. Any business that engages in credit card transactions must follow PCI-DSS requirements to safeguard cardholder information
There are 12 requirements for PCI-DSS v3.2 which are listed here.
The Prioritized Approach groups the 12 PCI-DSS standard requirements into 6 milestones to provide a roadmap in developing, implementing and monitoring security protocols and policies. It also helps assessors in evaluating security controls so there is more consistency in their auditing methods.
Read what the 6 milestones for PCI-DSS v3.2 are here.
PCI-DSS v3.2 is the newest standard version that was introduced in 2016. It revised and changed several of the standard requirements that were a part of the original PCI-DSS.
Read more about the newest version of PCI-DSS (v3.2) here.
Yes. Based on the discretion of the credit card company, acquiring banks can be fined from $5,000 up to $100,000 per month. Banks may pass off this fine to the business or merchant as well as increase transaction fees for the business or terminate their business relationship.
Yes. Compliance levels for PCI-DSS are based on the volume of credit card payment transactions that are made within a 12-month period. There are 4 merchant compliance levels defined by the Visa credit card brand .
Find out what the 4 levels of PCI-DSS compliance are here.
Major credit card companies such as MasterCard, Visa, Discovery, American Express, and JCB International created the Payment Card Industry Security Standards Council (PCI SSC) to help companies globally with their security systems when transmitting, receiving, using and storing cardholder information.
A penetration test must include manual testing, performed by qualified individuals who can accurately emulate the activities of a malicious user attempting to compromise the cardholder environment.
The PCI DSS requires internal and external network penetration testing, as well as application-layer penetration testing, as a means to find exploitable vulnerabilities.
PCI applies to ANY organization or merchant, regardless of size or number of transactions, that accepts, transmits or stores any cardholder data. Said another way, if any customer of that organization ever pays the merchant directly using a credit card or debit card, then the PCI DSS requirements apply.