Key Implementation Pitfalls When Deploying a HIPAA‑Compliant Email API
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Using a HIPAA-compliant email API is extremely important for the healthcare niche. But it’s not only about using it, you also need to know how to implement it, and that’s what really matters in the end. It’s very easy to encounter some implementation pitfalls, and even if that’s not a huge issue, you still want to know how to implement them properly.
How different HIPAA-compliant email solutions help?
Luxsci
Luxci offers HIPAA-focused API endpoints, as well as secure send solutions. They also have tokenized secure links, and you get excellent guidance in order to avoid some of the common PHI leaks that sometimes arise. The documentation separates the secure send points from the regular send, which matters quite a lot.
Paubox
Paubox offers a compliant API along with invisible encryption. It allows you to avoid the portal clicks, which does make it better for transactional workflows in clinics. And on top of that, it’s meant to enhance the process and make it a much better option. That being said, as a good HIPAA API, it tends to work extremely well in the low-friction settings.
Virtru
With Virtru, you have revocation controls and client-side encryption, which reduces relance on the vendor storage security. It can be great for those times when you want to augment an existing ESP with some stronger cryptographic protection. With that in mind, key management can bring in quite the complexity, so that’s certainly a thing to keep in mind with this type of stuff.
Zix by Webroot
When it comes to Zix, it has a very good gateway policy enforcement system. It’s very good for companies that have lots of senders. That being said, they automatically quarantine or encrypt stuff, and it definitely helps provide a more cohesive result and solution than you expect, which matters more than you might expect.
Sendgrid
While it’s not the most suitable for the healthcare world, they do offer good email marketing solutions. Implementing it can be simple thanks to the documentation that they provide. But overall, you are indeed getting a good value for money anyway.
Mailchimp
Mailchimp does not sign a BAA for the PHI cases, so you can only use it for the non-PHI stuff. You do need to confirm segmentation, that way the PHI lists are not mixed. Use that to your advantage, and you won’t have a problem adding that into the workflow.
Pitfalls you will encounter and how to solve them
You treat the TLS-only delivery as HIPAA-compliant
The problem that arises here is that relying on TLS or SMTP only or even just basic transport encryption is not always the best idea. It doesn’t offer the HIPAA compliance that you think it does, so try to keep that in mind. Transport encryption might protect the message during transit, but it won’t offer protection when this is in the vendor system, so that’s the thing you have to keep in mind here.
Not acquiring a BAA
If you are implementing the email API without signing the business associate agreement, that’s a problem. BAAs are a legal precondition when it comes to HIPAA. Without the BAA, you can’t really use the vendor in order to process PHI legally. That’s why even some of the largest ESP’s out there will not offer HIPAA eligibility. You have to be very careful when it comes to this type of stuff, and it will certainly convey a better value than expected.
A lack of planning for incident response
Issues can sometimes arise, so obviously, it makes a lot of sense to be prepared. You want to find ways to fully narrow down the compromised API key. It could also be a vendor outage, mass miss-send or anything of that nature. Narrowing down how to solve those problems effectively is always going to matter immensely, and you do want to test things out to see how they go.
The reason why this matters is because the HIPAA breach notification requirements and timelines are very strict. If you have inadequate reporting or delays, those will lead to various legal consequences. So yes, it’s very important and you do want to handle things in the most appropriate way possible. That will help you save both time and effort, not to mention money.
Inadequate retention and logging
The way you are logging and managing things also matters quite a lot, and you do want to address those problems in a very effective and comprehensive manner. With that in mind, if you don’t capture enough audit logs of who accessed what thing, that can also be an issue. That’s because HIPAA requires logging, along with ePHI audit access, which is a thing to take into consideration. Also, logs are necessary for breach reporting and investigation, which is something to take into account here.
You will also need to require vendors to offer access logs, not to mention configurable retention. Additionally, that needs to integrate with your SIEM. Tools like LuxSci provide audit trail support, and that’s why you want a good and reliable HIPAA-compliant API to work with. It will streamline this process more effectively, while still retaining great compliance and delivering very good results every time.
Assuming the marketing claims
You always need to check with the vendor about HIPAA eligibility. Because some vendors will mention it, yet that does not mean it will be something that they offer. And that’s the thing that you need to consider here. You want to provide consistent value and results, and once you do that, the results as a whole will be so much better.
Vendors could advertise features, but when it comes to them signing a BAA, some might not do it. And that’s why the best way to circumvent such a problem is to validate the product documentation. You want to get a signed BAA that names the API endpoints, storage scopes and encryption modes used. That way, it becomes easier to manage everything appropriately.
Mixing non-PHI and PHI in the same list
A very common mistake is that people tend to use a single marketing list for the PHI as well as non-PHI newsletters. Naturally, that is not going to be a good idea, and you need to figure out an effective way of dealing with that type of process. With that in mind, it does make sense to have separate systems for each one of the newsletters. That means tools like LuxSci for the HIPAA compliance and Mailchimp for the non-PHI newsletters.
Misconfigured policy rules
Sometimes, those policy rules might not be configured properly and that’s where things can get out of hand. The most important thing is to focus on tuning the DLP rules adequately. There can be aggressive blocking which stops some of the time-sensitive clinical messages. And if there’s under-detection, that will lead to HIPAA exposure. The truth is that you want to test DLP on the representative messages. And of course, you may want to consider using vendor support to try and tune the rules adequately. It will make things much easier, while still offering an exceptional value in the end.
Personalized templates with PHI
That’s a problem because if you use general templates, those could have important PHI info. That can include things like appointment reasons, lab values, diagnosis, personal identifiers and anything of that nature. The truth is that you want to audit all the templates to see if there are any PHI vectors in there. Ideally, you want to avoid PHI in the subject lines, and you may also want to use tokenized summaries, where possible.
If you can, also try to use secure links instead of offering any detailed clinical content. And while there, configure the DLP filters to detect as well as block any of the PHI patterns. In doing so, you get to maintain the HIPAA compliance, without worrying about legal complications.
Storing secrets and API keys in an insecure manner
It might be obvious, but the truth is that you always want to store the API keys and secrets securely. If you are using short-lived tokens, role-based service accounts and so on, that’s going to help quite a lot. A very good idea here is to try and use a multi-environment separation, and you also need to redact keys in the logs. That will provide more inherent protection, while eliminating any possible problems or issues which might become prevalent, so keep that in mind.
Conclusion
Make sure that the API you want to use is HIPAA-compliant and that it also offers all the necessary guidance when it comes to setup and implementation. Additionally, you want to review templates, manage content with vault keys, and also use secure API endpoints. Taking as many precautions as possible is always going to matter quite a bit, and the better you are addressing that, the better things will be in the end. It’s important to use the best API for this, and that’s why solutions like LuxSci are excellent, because you get secure endpoints, tokenized links and many other benefits!
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