5 Ways to Incorporate Agile Compliance Into Your HIPAA Audit Process

Ken-Lynchheadshot
Ken Lynch, Found & CEO of Reciprocity

Agile. The word comes loaded with technical meaning. Ten years ago, the software industry moved toward a cyclical process involving rapid iteration, quick improvements, and faster project development. As Agile Development has become ubiquitous in startups, it has also become applicable to many areas outside of software and hardware creation, particularly the healthcare field.

Agile companies do things faster by releasing smaller products that lead up to the whole. The constant revision and iteration of compliance processes requires multi-level planning and continuous testing. At its heart, agile development relies on the same processes that drive HIPAA compliance.

Thus, agile companies should be motivated to engage in agile compliance. In both development and compliance, agile methodology acts as a risk management tool that allows companies to expand into new markets. The agile compliance five-step process provides a framework that enables organizations to leverage compliance for increased profits.

Focus on the Quick Wins

Most CEOs assume the slog of compliance costs more than it’s worth. However, quick wins provide immediately visible benefits that drive customer development. For example, a SaaS application that initially focuses on law firms may also translate well to healthcare providers. HIPAA compliance, therefore, comes with a return on investment from entering a new market.

If you’re looking for quick healthcare compliance wins, start with controls that map across multiple standards. For example, SSL, laptop encryption, and two-factor authentication align with several standards, including the Health Information Trust Alliance (HITRUST) Framework. In addition, look for the repeatable and manual processes that can easily be automated to help drive a quick return on investment.

Iterate Every Review/Audit Cycle

Quarterly and annual review cycles create growth spaces for businesses. Every chance to better your organization is an opportunity to build customer trust. The proliferation of publicized data breaches in 2017 means that to earn customer trust your organization needs to consistently prove its attention to risk and its commitment to risk mitigation.

When reviewing healthcare compliance issues, an iterative process streamlines the administrative tasks that would otherwise slow down your audits. For example, conducting frequent internal audits and self-assessments means that your documentation is always at the ready.

The Health Care Compliance Association (HCCA) offers a compliance monitoring worksheet. One way automation can streamline your healthcare compliance efforts is by documenting the different roles employees play to ensure no conflict of interest. For example, the worksheet asks organizations to review which employees received conflict of interest forms. Agile automation provides a single source of truth that streamlines the review cycle with one click access to the documentation. SaaS compliance platforms offer information at a moment’s notice instead of forcing you to rifle through drawers of documents to ensure compliance.

This then streamlines your external audit practices because you not only compile the information faster but also can show proof of reviewing processes and controls that will ultimately lead to easier audit review.

Customer Risk is Compliance

Listening to customer needs is one piece of the compliance package that many businesses forget. Your organization sits in the middle of your customers’ compliance stream. Your risk is their risk, just as your vendors’ risks are your risks. This integration of multiple stakeholders calls for an awareness of your customers as internal stakeholders in your compliance process. Healthcare professionals need to keep their data safe, so they need their business associates to do the same. Not only do they need to trust you, they need you to prove you’re HIPAA compliant to ensure their own compliance success.

With this in mind, your business needs to focus on not just the compliance that leads to your success but also the compliance that leads to your customers’ success, such as engaging in SOC1/SOC2 reporting. Automated healthcare compliance solutions help you document your vendor management to prove that your business and business partners can protect Electronically Protected Health Information (EPHI). When you prove both your own HIPAA compliance and your effective monitoring of vendor compliance, you can coordinate with more healthcare service providers and expand your own business.

Data and risk drive your ability to listen to customers. Showing customers that your compliance not only meets, but actually exceeds, requirements demonstrates a shared goal that engenders trust and can be used to build better relationships.

Just Say No to “No”

In Utopia, all companies would be able to secure everything all the time. In reality, risk mitigation is the best anyone can do. To manage your risks, you need your c-suite to understand them. They don’t need to know the details, but they do need to see the big picture. Being a successful CISO or CIO no longer means just getting the work completed. It means engaging multiple departments and helping other internal stakeholders understand how they are affected by compliance. While silos can complicate this process, finding the right tools can make it easier.

Controls matter, but controls that stifle speed of delivery hinder. Risk mitigation comes with judgment. Emergencies happen. Your organization will be vulnerable to risks if you say no to a fix and wait to deploy a solution because a compliance requirement says that “all code must be tested.” If your company waits to deploy a bug fix because of a compliance requirement, it puts itself at greater risk of losing customers because its product is broken. Balancing standards and regulations with  functionality highlights the importance of agile to both development and compliance.

Continuously Test

Continuous testing in compliance means ongoing monitoring, constant vigilance, and systematic reviewing of risk management decisions. As information security audit work increases exponentially, organizations need to enable strategic risk management to respond faster to broken controls. In IT, companies need to continuously deploy. In compliance, companies need to be prepared to be audited at any time. If customers need you to be HIPAA compliant, they may want to do an independent audit as part of the corporate partnership. This means that if you’re not continuously testing, you’re not going to meet those customer needs.

Preventative controls in healthcare include ongoing monitoring of your internal controls system. This includes an ongoing review of your input controls, processing controls, output controls, and software licence compliance controls. If your firewall needs to have a vulnerability patch, do it as soon as possible or risk a potential breach. The right automation system can help you see into your program and provide you with information about critical software updates that can help you instill trust in your customers.

Agile compliance, like agile development, makes healthcare companies more flexible in the marketplace and more profitable in the long run. By focusing compliance efforts into a series of quick wins followed by continuous review and revision, organizations can leverage increased customer trust for significant returns on investment.