P1: "Alissa Knight has spent the last year focusing on hacking
Fast Healthcare Interoperability and Resources (FHIR) APIs,... #HackingFHIR
Yup, I read her last report on a related topic, and can attest there's a big investment in time, and her credentials are solid as a white hat hacker #HackingFHIR
Also page 1: Graphics are awesome, but also intense, and somewhat dark. There's some really solid attention to presentation #HackingFHIR
#HackingFHIR
Table of Contents is 3 pages for 14 lines of text and lots of art. Good if you like art. Speaks of attention to presentation, and good marketing. Most policy people seem to avoid art.
For context, this material is presented in the same way that we'd see a commercial marketing piece, but way better done. And it is in fact just that, but also more, the content is also likely better done b/c attention to fine detail. #HackingFHIR
It requires hard work to unflip the bozo switch (see simulationpl.com/blog/newslette…) that marketing content does for most of us. Do it. You will be glad you did. #HackingFHIR
A point that security professionals like @alissaknight will understand.
Provenance is important. When it is suspect, so is your content. Marketing content does not present good provenance.
But for others, there are many sources of provenance. Use them all. #HackingFHIR
A lot of the shit-storm that this report has kicked up stems from the marketing origin. Stop caring about that. Get the facts from it, and unhype the data. Interpret what you read, instead of just intuiting from surface presentation. #HackingFHIR
Damning summary on Page 5
“An effective kill chain in the targeting of the healthcare industry will not be of the EHR ... but in the third-party FHIR aggregators and third-party apps ... where security has been found to be flagrantly lacking." -- @alissaknight
Someone (@ONC_HealthIT) should take note: Rushing to market can lead to dangerous inattention to security.
"My malaise grew quickly over the past six months as the healthcare industry rushed to meet regulatory deadlines ... [b/c of fines] tied to this new law."
In fact, @GrahameGrieve is quoted in the report: "I want to thank Alissa Knight for shining the spotlight on our
industry's security practices. I look forward to a follow up
report where she has to work much harder to find security issues in FHIR implementations.”
This is not about #FHIR. This is about implementations.
"Vulnerabilities discovered in this research are not
inherent to FHIR. Remember that FHIR is only a “blueprint” or framework and how it is
implemented is up to the implementor."
Deep shit: Vulnerabilities in one specific mobile app for medication and prescription management allowed
me to make unauthorized changes to other patient records besides my own.
OK, so this is the big surprise to me. At least 25 apps made it to market without adequate security testing.
Checking for embedded tokens should be part of ANY application security scan, #HealthIT or otherwise.
"For the vulnerabilities allowing me
unauthorized access to other
patient data, I was logged in as a
patient that should have limited
scope to just my records."
"With one patient engagement app,
the API endpoint sent me all the
patient and clinician records in its
database, indicating it was using
the mobile app to filter out just my
record."
I cannot actually interpret the graphics on page 17 because they lack explanation. There's a standard way in research to report a) the nature of the data, and distinguish that from b) the results. It's not clear whether tables on page 17 represent a or b or both.
I think @alissaknight should read some @EdwardTufte. The charts on page 17 clearly have been through marketing hands. The scales aren't labeled and don't make sense, the heights don't line up.
There's a way to present this that I've learned from my MBI program through @OHSUInformatics. This research report would have benefitted in reporting in that fashion. Sure, use cool graphics, but present the expected material in the expected order.
I'd love to ask @williamhersh to grade this as if he were grading a research report, based solely on expected content (not formatting or style). It would be lucky to get a C. That doesn't mean the content in this report is bad. Far from it.
I got a D in geometry in 10th grade not because I couldn't come up with the right answer, but because I always skipped the (to me) obvious steps. This report does that too.
We know that 4 healthcare institutions and 48 apps were tested, but how many companies? And how many apps from the same company? There has to be at least 4, and at most 46 (though unlikely), probably somewhere around 25-ish. But that number is not reported yet.
Why is that important? Because I cannot interpret the results without understanding the population behind the data for the results being reported. If you report on quantities (or percentiles) for companies, you need to give me N for companies.
This is an interesting comment:
"If there existed some formal certification body for apps, and the certification status of a given app could be programmatically verified ..."
A day or two of research would have greatly added value to this report. How many of these Apps were HACP, HonCode certified or developed by a HITRUST certified company?
We don't know, and I suspect that @alissaknight doesn't either, a follow-up would be good.
These last two pages expose a weakness in the report. There's great data right alongside a failure to do the right research. How do I trust this report?
That's what deep reading will do for you. This isn't a peer reviewed article. But it still has good stuff.
Dynamic client registration, mentioned at the end of this report (see datatracker.ietf.org/doc/html/rfc75…), is still a work in progress. Not in standards, but in deployment. #HealthIT is behind general IT in deployment of this kind of thing, my guess is by about 2-3 years.
This should likely be a Condition of Certification from @ONC_HealthIT :
Require that FHIR app developers & data aggregators perform regular penetration testing that includes static & dynamic code analysis of their apps before connecting into production EHR systems.
Sadly, it seems that others laws might need to be in place to enable @ONC_HealthIT to regulate what constitutes good security and privacy practices that might be applied by Health Information Networks as defined in 45 CFR 171.102 ecfr.gov/current/title-…
This is another interesting recommendation:
Mandate that certificate pinning
be implemented on all SMART on
FHIR mobile apps.
Which experts do we listen to and when? And just as for doctors or lawyers, with N security professionals in the room, one is likely to get M > N opinions.
"Adversaries don’t need to attempt to
breach hospital networks in order to
get to the EHR data anymore with the
introduction of this new ecosystem of
apps and data aggregators being built
on top of them."
And I'll add to that, if your present investment is zero, the threat to your organization's capacity to survive is greater than you can bear. One caught screwup can cost you millions. The price of a decent penetration test is a 3-4 order of magnitude lower.
To summarize, this is a good report, with a lot of good data you need to take seriously. It has some problems that make that difficult. Ignore it at your own peril.
Understanding the report author's goals and motivations, both personal and professional is an important key in understanding how to read a report like this. In terms of COI, I think this report had two MILDLY questionable statements in 57 pages.
... #HackingFHIR
In terms of quality, the content here, with a few small modifications, could easily make it through peer review.
I've seen worse in peer reviewed journals, and the art isn't nearly as good.
OK, now it's time to review @AMugge's rule, more formally titled: Medicaid Program; Patient Protection and Affordable Care Act; Reducing Provider and Patient Burden by Improving Prior Authorization Processes, and Promoting Patients’ Electronic Access to Health Information for...
Medicaid Managed Care Plans, State Medicaid Agencies, CHIP Agencies and CHIP Managed Care Entities, and Issuers of Qualified Health Plans on the Federally-facilitated Exchanges; Health Information Technology Standards and Implementation Specifications
A title so long, it fills two tweets.
Simplified it's the second full length novel in the Payers on FHIR series from CMS, subtitled the Beginning of the End of EDI
#NewHIPAA Proposed Privacy Rule Thread starting. These are my notes, there'll be a blog post summarizing these later. 1/??? And I'm not even going to try to count these or tag all with #NewHIPAA, I'll just keep them in this thread.
Basically this is needed because healthcare providers say "I can't do that b/c HIPAA, and patients say "yes you can", and lawyers say "but ...", and trees, we need to save some trees.
A lot of the input on this rule came from a request for information in 2018.
The big points are: Give me my damn data, and let me take notes, and do it faster, and you can get it in the form and format that you ask for, w/o having to bring umpteen forms of id, clarifying when you can be charged, changing the fee structure, making fees more transparent ...
If it looks to you like the exponent on infection growth rate is increasing, you are probably right. I just looked at the 5-day LOGEST values (estimate the exponential growth based on last 5 days activity), and the rate has risen 4 out of the last 5 days. Testing just started...
So, this isn't scary to me YET. What it means is not that the real exponential growth rate of infection is increasing, but rather that the rate of our knowledge of exponential rate is increasing. But more testing is still needed to get the numbers to settle down ...
There's gonna be lots of numbers for the epidemiologists and hyper-mathy folks to study RE impact of testing volumes (see ) on estimates of real growth rate when this is over. I don't recall signing up for that clinical trial though.
O for a Muse of FHIR, that would transcend
The brightest HL7 of invention,
A country for a stage, CEOs to act
And patients to behold the swelling scene! #Cures#VHC
Then should the humble Posnack, like himself,
Assume the port of Mars; and at his heels,
Leash'd in like hounds, should famine, sword and fire
Crouch for employment. #Cures
But pardon, and gentles all,
The flat unraised spirits that have dared
On this unworthy parchment to bring forth
So great an object: can this cockpit hold #Cures
Starting at page 221 with the regulation itself (see how I do this...I skip to the regs first, I’ll go back through the preface material later) #PatientAccesscms.gov/Center/Special…
In the following, mom is simply how I think about the phrase "Medicare Enrollee". It could be dad, uncle Fred, my buddy Glen et cetera. #PatientAccess is about the patient.
So, mom's MA organization has to provide APIs that allow her to use an app (after mom approves it) to access standardized claim data, adjudications, appeals, provider payments (remittances) and co-payments (cost-sharing) within one business day of claim processing. #PatientAccess