Disaster Recovery Plan: Are You Prepared?

Disasters, originating from natural causes, system failures, or human errors, can occur unexpectedly and result in significant damage. Having a comprehensive disaster recovery plan, complete with a thorough data backup strategy, is crucial. The HIPAA Security Rule requires all Covered Entities (CEs) to develop a disaster recovery plan. The plan details agency actions in the event of a natural disaster or other risks that could disrupt normal operations. Are you adequately prepared?

Contingency Plan

Federal law requires that CEs and providers implement protocols to safeguard and ensure electronic Protected Health Information (ePHI) access. This includes a contingency plan to maintain access to ePHI during emergencies or disasters.

However, ePHI can only be accessed through data processing applications like Electronic Health Records (EHR) or Practice Management System software. Therefore, the utilization of these systems must be considered during the contingency planning and recovery process.

Data Backup Plan Methods

Most data recovery centers recapture ePHI following system failures through either data backups or replication:

Data Backups

Backups are for removable media such as CDs, flash drives, etc., or storage systems such as dedicated backup appliances. The backups are typically taken regularly, duplicated, and stored both on-site and off-site to maintain multiple versions of the data.

Data Replication

Data replication copies ePHI to another site, a host, network, or storage facility. Replication can be scheduled or done in real-time while the information is modified (synchronous mirroring).

Data Backup Plan: Site Types

Utilizing an alternate or secondary site is crucial for a successful recovery plan that complies with HIPAA regulations. Typically, there are three options available:

Cold Site

Provides power, cooling, and networking only. Servers, switches, and storage hardware must be provided separately. If you opt for a cold site, the necessary hardware and backup data must be shipped to the site.

Warm Site

Includes enough servers, switches, and storage hardware to support ePHI operations during a disaster. If choosing a warm site, backup data needs to be transported to the site.

Hot Site

Offers warm site hardware and continuous ePHI mirroring to expedite disaster recovery.

For all three site types, servers, networking, and software systems will require on-site reconfiguration to support emergency operations. Additionally, periodic testing should be conducted to ensure proper functionality.

Disaster Recovery Plan (DRP)

You must also implement a disaster recovery and emergency mode operations plan. The data backup plan establishes systems for the recovery of all ePHI. Disaster recovery planning establishes protocols necessary to ensure the restoration of ePHI in case of loss. The emergency mode operation plan allows business operations to continue, safeguarding ePHI during an emergency.

Many HIPAA compliance consultants integrate both mandates with an integrated Disaster Recovery Plan (DRP). Any DRP should encompass the following:

Disaster Declaration

ePHI might comprise a significant disaster, such as a hurricane, that requires a practice to work in an alternate location. The disaster declaration identifies the decision process to address and the key players involved.

Disaster List

Classifying high-probability and high-impact events can support investment in expensive backup systems, alternative site(s), and revision procedures.

Data Backup

The DRP should detail the data backup procedures. It should include the type of backup system, location(s) of any off-site repositories, and the frequency at which the data is copied. In the case of removable device backups, how the data is shipped to the alternate site (including activation protocols, vendor contact details, and instructions on how practice staff would access and/or travel to the alternate site) should be documented.

It should also be demonstrated that any off-site repositories are far enough away from the practice location (and any other backup locations) to ensure safety in the event of a natural disaster impacting the primary site.

ePHI Recovery

Ultimately, the whole point of a DRP is to restore ePHI in a safe environment so that healthcare organizations can continue treating clients. DRPs should identify all ePHI systems – including your EHR – and all sensitive data requirements. They should also outline the procedures to restore these systems, including a recovery priority list and the contact information for staff members familiar with these emergency operations.

In addition to these requirements, don’t forget that changes to ePHI applications (such as an EHR) can change the DRP. Regular modification and testing are necessary to ensure that you’re current and up to date. You should also periodically check for updates to DRP requirements to ensure you follow the most current rules.

“Periodic plan tests and resultant corrections are vital to the continuing success of any disaster recovery. With natural disasters and security breaches occurring more frequently, the need for a practicable DRP is more essential than ever.”

See our Compliance Resource Center for more complimentary tools.

PIMSY Specifics

Every EHR is different. Check with your vendor for detailed specifics about how it might help your organization’s HIPAA disaster recovery plan. With PIMSY, your agency data is stored in the Microsoft Azure Cloud, automatically backed up, and encrypted at multiple locations. Microsoft Azure (a “hot site”) adheres to HIPAA protocols, adding another layer of compliance and security.

Every agency is individually responsible for a HIPAA contingency plan. Using PIMSY for your mental health software greatly increases compliance and data security for HIPAA. While you still have to establish a DRP, its mechanics are taken care of simply by using PIMSY EHR.

For details about how PIMSY’s EHR solutions can help you meet compliance regulations, contact us: 877.334.8512 – hello@pimsyehr.com