From Legacy to Resiliency: A Roadmap for Modernizing Healthcare Infrastructure Securely

Many healthcare organizations continue to rely on legacy technology to process sensitive information, including regulated electronic protected health information (PHI). While this may seem like a cost-effective solution, especially for SMBs with limited financial resources or technical expertise, it can be risky and costly. A data breach or processing error involving HIPAA-regulated data can result in substantial fines and reputational damage that is difficult to repair.

This article examines the risks to your organization associated with legacy technology and the benefits of moving to a HIPAA-compliant cloud solution. Then, we present a methodical approach that ensures a successful cloud migration, providing better protection for your organization and the sensitive HIPAA data you process.  

Risks of Legacy Technology for HIPAA Workloads

Organizations processing HIPAA workloads with legacy technology face multiple risks that threaten their ability to comply with regulatory standards by protecting the privacy, security, and availability of patient data. 

• Security vulnerabilities: Legacy systems may be running obsolete or unsupported operating systems or applications. Threat actors can leverage known vulnerabilities that cannot be addressed and mitigated with security updates and patches. 

• Insufficient data protection: Older systems may not support the end-to-end encryption necessary to protect HIPAA data. Organizations may face challenges implementing identity and access management (IAM) tools, such as multi-factor authentication. 

• System failure and data loss: organizations risk extended downtime when utilizing legacy software or older hardware. Organizations may experience data loss and limited access to critical medical information due to outdated backup systems and inadequate disaster recovery plans.

• Limited monitoring and breach response capabilities: Legacy systems may not provide the real-time monitoring needed to protect data resources against sophisticated threat actors and internal threats. Organizations may experience delayed breach notification and response activities, leading to the exposure or compromise of patient data. 

• Limited performance and scalability: Organizations may be unable to improve legacy technology’s performance to meet the requirements of modern healthcare workloads. Teams cannot effectively scale on-premises systems to handle growth effectively.

• Inadequate audit capabilities: Organizations must be able to provide audit trails and documentation to demonstrate compliance during HIPAA audits. Teams may struggle to produce the necessary artifacts due to legacy systems and applications. 

• Rising costs: Organizations must absorb the costs of expensive replacement parts and specialized technical skills to support legacy hardware and software. 

The Advantages of HIPAA-Compliant Cloud Solutions

Healthcare organizations can effectively address the risks of legacy systems by migrating their regulated environment to a HIPAA-compliant cloud platform. Organizations can significantly improve their HIPAA compliance posture by utilizing a HIPAA-compliant cloud solution. The cloud service provider (CSP) assumes responsibility for providing infrastructure and services that meet HIPAA standards. Customers are ultimately responsible for safeguarding sensitive data by effectively using cloud infrastructure. 

The following specific advantages make a cloud platform a practical solution for businesses processing HIPAA-regulated data. 

Data Security

CSPs that provide HIPAA-compliant solutions strengthen data security through multiple tools and policies.

• End-to-end encryption is enforced for all regulated data in transit and at rest to ensure it can be used only by authorized entities.
• Monitoring and intrusion detection tools mitigate threats to data resources. Real-time intrusion detection systems identify and automatically respond to issues.
• Data access is strictly controlled with measures such as multi-factor authentication and role-based access controls (RBAC). These controls limit external and internal threats to healthcare data. 
• Providers can generate detailed audit trails to review data usage and document compliance with security and privacy rules. They streamline a company’s ability to address HIPAA audit requirements. 

Data availability and disaster recovery

Organizations must meet HIPAA’s stringent data availability requirements to avoid penalties for noncompliance. HIPAA-compliant cloud solutions offer multiple strategies to improve availability, including:

• Redundant and geographically distributed data storage;
• Automated and encrypted backups of all regulated data;
• Streamlined, automated recovery procedures to minimize downtime.

Disaster recovery is an essential component of a comprehensive data availability strategy. CSPs provide automated and efficient disaster recovery capabilities that protect your business from man-made or natural disasters. Customers can recover in different geographic regions to avoid the effects of regional events. Organizations gain enhanced resiliency with a cloud solution that is impossible with legacy systems. 

Scalability and flexibility 

Scaling on-premises environments is difficult and expensive. Organizations can instantly scale with cloud resources to address evolving workloads without significant capital expenditures. Cloud customers can also typically upgrade performance to handle the requirements of modern healthcare initiatives such as remote patient monitoring, telemedicine, and AI-enhanced analytics. Organizations can gain and maintain a competitive edge by leveraging the scalability and flexibility of a cloud solution. 

Compliance management 

CSPs offering certified, HIPAA-compliant environments have automated tools that perform compliance auditing, monitor user access, and generate reports to document compliance. The automated tools relieve your team of this responsibility, minimizing the possibility of human error that can result in a non-compliance penalty.

Cost efficiency

Organizations can reduce capital investments in hardware and data center space by migrating to the cloud. Teams can minimize operational costs by using CSP’s pay-as-you-go pricing models, which charge customers only for actual resource usage.

How to Migrate to a HIPAA-Compliant Cloud Solution

Healthcare organizations should adopt a methodical approach when migrating to a HIPAA-compliant cloud platform. Businesses, especially SMBs with limited technical staff and resources, should strongly consider engaging an experienced technical partner to facilitate a successful migration. 

Perform a comprehensive assessment

The essential first step is to conduct a comprehensive risk and readiness assessment of your current environment. The assessment has multiple objectives, including:

• Identifying all systems and applications that contain PHI across the entire environment;
• Mapping how PHI is used between systems and applications;
• Evaluating security measures and access management policies;
• Determining gaps in existing procedures that may result in non-compliance.

Decision-makers should expect an inventory of PHI systems and a security gap analysis from the assessment. This data will be crucial when deciding the order of system migration and ensuring the security of the new environment. 

Select a HIPAA-compliant cloud provider

Organizations must work with certified HIPAA-compliant CSPs to ensure the solution meets all regulatory standards. Prospective CSPs should be able to demonstrate their compliance with HIPAA, HITECH, and other security standards. The CSP must be willing to sign a Business Associate Agreement (BAA) with the customer. The BAA is a mandatory HIPAA requirement that defines the CSP’s responsibilities in maintaining compliance.

The provider should offer advanced security and data protection services, including end-to-end encryption, intrusion detection systems, and access management. They must ensure the physical security of their data centers and offer geographic redundancy to enhance resiliency.

Define your migration strategy

Your organization needs to develop a migration plan that aligns with business and compliance objectives. The company may be moving its complete environment or select systems that process regulated data. The migration plan should include the following components.

• A migration model must be selected, for example, between a cloud-native approach and a more traditional lift-and-shift strategy, which moves the existing environment to the cloud. 
• Decision-makers must prioritize the order to migrate applications and data resources.
• Teams must develop plans to minimize downtime and service disruption during the migration.
• Organizations must include a HIPAA compliance check in all migration phases to ensure data is handled appropriately. 

Architect a secure cloud environment

The cloud environment must ensure complete PHI protection to meet compliance standards. Organizations should construct systems that consider the following best practices.

• All data should be encrypted in transit and at rest, using protocols such as AES-256 for data storage and TLS for secure transmission.
• Organizations should practice network segmentation and virtual private clouds to reduce risks to regulated data.
• Teams must enforce RBAC and multi-factor authentication to limit access to sensitive data.
• The environment should be protected with intrusion detection and prevention systems and advanced event management tools. 
• The team can support compliance by configuring automated audit logs and resource-monitoring dashboards.

Perform the data migration

Teams must use secure transfer protocols to migrate data to the cloud. Data should be encrypted at all times, with its integrity verified upon reaching the cloud. All data transfers should be documented, and migration logs compiled for compliance documentation. 

Implement HIPAA compliance controls

Organizations must enforce controls to support the technical, physical, and administrative safeguards of HIPAA. Examples include access controls with unique IDs, data integrity controls verified with checksums, and audit controls with log retention. Teams must update policies and procedures to reflect the new environment. Organizations may need new disaster recovery and incident response plans. Staff must be trained on the latest systems and their responsibilities.

Test post-migration security and resiliency

Teams should validate security in the new environment with a series of reviews and tests that include:

• Penetration testing and vulnerability scans;
• Access control audits;
• Audit log verification;
• Disaster recovery testing.

Teams must take the appropriate action to address issues identified during this testing.

Maintain continuous monitoring

Organizations must continuously perform compliance monitoring to detect unauthorized access and anomalies that may indicate insider threats. All employees handling PHI must be trained, with the training documented annually. Decision-makers should review and update BAAs as business requirements change.

Migrate to Modernize and Protect Your Business

Your healthcare business cannot afford the financial and reputational damage of a data breach involving PHI or a non-compliance finding during a HIPAA audit. Organizations that migrate from legacy technology to HIPAA-compliant cloud solutions minimize the risks to PHI protection and HIPAA compliance. The key for SMBs is to find a certified, reliable partner that provides the technical support you need to safeguard your business.