THE HIPPOCRATIC OATH MUST EXTEND TO THE BUSINESS OFFICE: CONFRONTING AND RESOLVING THE ETHICAL DILEMMA OF OFF-SHORING MEDICAL RECORDS.
by Elizabeth Burke, Patient Privacy Advocate
In the winter of 2019, 45,000 patients of Rush System Health in Chicago and 6,300 patients of Emerson Hospital in Concord, Massachusetts were informed of an incident in which their private medical data was exposed in identical security breaches. The two hospital systems and Miramed, the company who handles their medical claims processing, have not publicly named the individual responsible for this breach, despite claiming to have reported the incident to law enforcement and completing a “detailed forensic investigation.”
If you have ever gone to the doctor or a hospital you have an electronic medical record. Contained within this digital database is a wealth of information about you including, but not limited to, your full name, date of birth, address, social security number, sensitive photos of your body, health insurance information, payment information, place of work, next of kin, members of your household (and in some cases their personal information), a catalog of your physical and mental health history, every blood test result, every prescription and every diagnosis, both past and present.
The information in your electronic medical record is profoundly personal and identifiable. To address this vulnerability the 104th United States Congress and President Bill Clinton enacted the Health Insurance Portability and Accountability Act (HIPAA) on August 21, 1996. This legislation provides security provisions and data privacy to keep patients’ medical information safe.
When a US-based healthcare professional violates HIPAA they are held personally responsible for their actions both criminally and civilly. The criminal penalty for a willful violation of HIPAA can cost the offender between $50,000 and $250,000 and up to five years in jail.
This is not true for a work force in a foreign country. The Health and Human Services Office of Civil Rights, which is responsible for enforcing HIPAA, does not have extra-territorial reach. This means that an individual of an off-shored work-force does not face the same penalty that a US based professional faces. There is nothing to lose when a healthcare professional in another country violates HIPAA.
So, it shocks most Americans to hear that in some cases their un-redacted medical records are being accessed by foreign work-forces who are not held accountable to HIPAA. This phenomenon is the direct result of the digitization of health records which has allowed a US based workforce to be replaced by cheap labor from foreign countries such as India, The Philippines, and Pakistan.
This brings us to the two identical data breaches that I have reason to believe involved an off-shored workforce. 45,000 patients of Rush System for Health in Chicago, Illinois and 6,300 patients of Emerson Hospital in Concord, Massachusetts had their names, addresses, birthdates, social security numbers and health insurance information compromised through a third party vendor.
The vendor who admitted to the breach is Miramed. Miramed, in their own words, “stands as the premier global provider of business process outsourcing solutions [for] healthcare organizations nationwide.” They are also known for hiring off-shored work-forces in India and The Phillipines to handle medical insurance claims processing. In response to this data breach Emerson hospital claimed in a press release that “A detailed forensic investigation showed that the files were of such poor quality that a third-party did not find the data useful.” Basically assuring everyone that yes, their information was stolen, but don’t worry, most likely no one can do anything with it. Additionally, Miramed reported that the individual who compromised this data has been fired and the incident reported to law enforcement.
However, when I called the police departments in Massachusetts, Illinois, and Michigan (Jackson Michigan is the corporate headquarters of Miramed) as well as FBI field offices in an attempt to find out more about the investigation, I could find no record of Miramed filing charges related to this data breach. None of these entities appear to have been the law enforcement agencies that Miramed claimed it contacted. So, who completed the “detailed forensic investigation?”
More importantly, why was the offender merely fired? Under HIPAA, this individual should be facing criminal charges which would eventually be made public, yet I have been unable to find the name of the law enforcement agency that conducted the investigation or any charges filed.
During my investigation of The Emerson Hospital and Rush Health System data breaches I called Miramed on four separate occasions. I identified myself as a patient privacy advocate and asked for the name of the law enforcement agency to which Miramed claims to have reported the breach. They have acknowledged that I made multiple calls and informed me that they would not be answering my questions.
My questions remain and I will now ask them publicly: A crime has been committed, what law enforcement agency is handling this investigation? Who performed the forensic investigation that determined the breach to be “low risk” as described by Deb Song, hospital spokeswoman for Rush System for Health? Did this breach happen in the United States? I can only hope that Miramed will answer these questions and release the name of the person responsible for this data breach.
It’s also important to remember that this data was collected and disseminated in the delivery of life-saving healthcare. Should a seven year old receiving chemotherapy treatment have this level of personal exposure? Is that the price of getting treatment for cancer? There is a saying, “The walls of hospitals have heard more prayers than the walls of churches” and it perfectly captures the sacred trust that patient populations put in their healthcare providers.
Patient populations are owed the full scope of privacy that HIPAA promises them. Undermining HIPAA by off-shoring the processing of medical claims makes patient populations vulnerable and leaves no avenues for justice. The last thing a sick person needs to deal with is trying to wrest their identity back from the hands of someone who got it via the very place they sought treatment.
July 4, 2021 @ 6:46 am
Fahrud – natural pills for erectile dysfunction Vnsrje
July 7, 2021 @ 11:40 am
priligy – generic cialis canada online how to get cialis from canada
July 8, 2021 @ 4:27 pm
best erectile dysfunction pills – cheap ed pills brenda 35 ed contraceptive pill
July 10, 2021 @ 6:48 pm
prednisone 6 mg – prednisone 50 mg cost prednisone 20mg by mail order
July 12, 2021 @ 2:06 am
provigil 100 mg – vigilpr provigil dosage
July 13, 2021 @ 5:20 am
accutane india cost – accutane price in canada accutane online prescription
July 14, 2021 @ 4:00 am
amoxicilin brand name – where to buy amoxicillin amoxicilina 500 mg
July 15, 2021 @ 3:10 am
where to buy vardenafil in canada – buy vardenafil on line discount vardenafil online
July 16, 2021 @ 4:57 am
is ivermectin a prescription drug – ivermectin us where to buy stromectol online
July 17, 2021 @ 3:24 am
discount cialis generic – generic tadalafil 20mg india cialis online pharmacy us
July 18, 2021 @ 4:13 am
stromectol pills canada – ivermectin pills canada ivermectin 3 mg tablet dosage
July 19, 2021 @ 4:40 am
accutane for sale uk – accutane price usa where to buy accutane online uk
July 20, 2021 @ 5:49 am
how much is lyrica in mexico – walmart pharmacy prescription drugs online
July 21, 2021 @ 4:59 am
amoxicillin price without insurance walmart – can you buy amoxicilin over the counter buy amoxicilina 500 mg
July 22, 2021 @ 8:46 am
how to buy viagra – viagra 4 sale viagra australia over the counter
July 23, 2021 @ 11:42 am
tadalafil india – can you buy cialis over the counter usa price for generic cialis
July 24, 2021 @ 8:10 pm
stromectol tablets buy online – ivermectin 90 mg ivermectin australia
July 25, 2021 @ 9:41 pm
prednisone in india – buy prednisone 5mg prednisone 5 mg tablets
July 27, 2021 @ 4:36 pm
provigil dosage – modafinil addiction modafinil for sale
July 27, 2021 @ 11:52 pm
dating sites for over 50
dating websites
July 29, 2021 @ 2:30 am
personals free
dating older men
July 29, 2021 @ 5:22 pm
buy azithromycin 500mg online – zpak can you buy zithromax online
July 30, 2021 @ 5:33 am
free single personal ads
accra ghana dating scammers list
July 30, 2021 @ 2:34 pm
free local singles
dating sims
July 30, 2021 @ 11:01 pm
furosemide buy no prescription – furosemide brand name australia furosemide tablets 40 mg for sale
August 2, 2021 @ 9:29 am
clomid online – generic clomid purchase clomid
August 4, 2021 @ 5:57 pm
best women viagra pills – can you buy sildenafil online generic viagra soft tabs
is sucralose keto
August 6, 2021 @ 10:28 am
keto vegetables https://ketorecipesnew.com/
August 6, 2021 @ 10:27 pm
5 mg cialis – tadalafil canada generic over the counter buy cialis 5mg online
August 7, 2021 @ 12:49 am
top 5 gay dating sites
gay dating site phone number
free gay latino dating
August 7, 2021 @ 9:44 am
i’m dating a gay asian man
gay dating sa
gay dating scam military guy
August 7, 2021 @ 5:22 pm
gay dating in orlando
gay dating men with six packs
gay piss fetish dating site
August 8, 2021 @ 12:55 pm
ivermectin stromectol – stromectol tablets india ivermectin
August 8, 2021 @ 6:16 pm
dating websites for gay men
gay dating tampa
syracuse gay dating
wedgie gay dating
August 9, 2021 @ 12:22 pm
gay dating j https://gaychatrooms.org/
gay furry dating sim game
August 9, 2021 @ 7:06 pm
atl gay dating https://gaydatingzz.com/
sugar daddies gay dating
August 9, 2021 @ 7:51 pm
gay dating website india https://gaychatgay.com/
August 10, 2021 @ 1:33 am
betfair casino online – online casino casino online
August 11, 2021 @ 4:26 am
local gay teen dating webistie
gay polyamorous dating site
gay 15 year old dating site
August 11, 2021 @ 1:04 pm
gay dating symbols
gay dating in med school
gay italian dating site
August 11, 2021 @ 3:54 pm
medications that cause erectile dysfunction – mens erection pills what is the main cause of erectile dysfunction
August 11, 2021 @ 8:23 pm
gay dating french
lancaster sc gay dating
gay dating truckers tubes
August 12, 2021 @ 8:09 pm
dating a bodybuilder gay
free gay chat and dating usa
gay dating sex sites 2021
August 13, 2021 @ 12:27 am
prednisone cream otc – prednisone 10mg prednisone tablets
August 14, 2021 @ 2:57 am
100% free bear gay dating
gay dating sites for married
non hookup gay dating sites
August 14, 2021 @ 10:38 am
cheap generic india viagra – viagra india price lowest price viagra
August 14, 2021 @ 11:26 am
gay speed dating atlanta ga
gay daddy bear site dating
surge gay dating site
August 14, 2021 @ 6:32 pm
bi gay dating sites
gay dating near me
rochester gay dating
August 15, 2021 @ 6:06 pm
dating trans girl is being gay
united states gay dating sites
rules of gay dating
August 16, 2021 @ 4:35 am
online cheap tadalafil – Canadian healthcare cialis online cialis in canada
August 17, 2021 @ 12:41 am
gay dating sites in usa
gay catholic dating
dating gay lesbian services
August 17, 2021 @ 9:12 am
gay dating los angeles ca
bro4bros gay dating
best gay dating sims
August 17, 2021 @ 4:25 pm
georgia gay dating
gay dating events
is being dating a trans guy gay
August 17, 2021 @ 8:59 pm
stromectol buy – ivermectin uk coronavirus stromectol ireland
August 19, 2021 @ 5:17 pm
cure for ed – online medication buy erection pills
August 22, 2021 @ 11:10 am
ventolin generic – onventolinp.com ventolin generic
August 24, 2021 @ 12:34 am
can i buy cytotec over the counter in south africa – cost cytotec generic cytotec
August 25, 2021 @ 7:40 am
doxycycline order online uk – can i buy doxycycline over the counter in south africa doxycycline hyclate 100 mg capsules
August 26, 2021 @ 8:25 pm
neurontin 100 mg capsule – neurontin 1800 mg where can you buy levothyroxine
August 28, 2021 @ 8:57 am
sildenafil 100mg prescription – viagra 100mg cost in usa
August 29, 2021 @ 4:38 pm
affordable pharmacy – cialis soft tabs uk cost of cialis in canada
August 30, 2021 @ 8:16 pm
what is vardenafil used for – order vardenafil without prescription buy brand vardenafil online
grindr gay dating website
September 1, 2021 @ 9:07 am
speed dating philadelphia gay https://freegaychatnew.com/
September 1, 2021 @ 9:07 am
ivermectin over the counter canada – stromectol for head lice stromectol 3 mg tablets price
September 2, 2021 @ 4:43 am
latin gay men dating
kinky gay dating san diego
gay dating flash games
September 2, 2021 @ 10:13 am
6 prednisone – prednisone 54 cost of prednisone in canada
September 2, 2021 @ 1:48 pm
black gay online dating
gay mormon dating site
lesbian gay dating listmail
September 2, 2021 @ 9:16 pm
gay teen dating we
gay trans dating sites
gay male s and m dating sites
September 3, 2021 @ 5:28 pm
accutane price nz – accutane 10 mg discount buy accutane from india
September 3, 2021 @ 10:17 pm
capr coral gay dating
gay dating in japan
gay dating coach hitch
September 5, 2021 @ 5:44 am
amoxicilin brand name – avatar de price of amoxicillin without insurance buy amoxicillin 500 mg from canada
September 5, 2021 @ 3:33 pm
free gay dating men
gay dating sites nz
gay senior online dating
September 5, 2021 @ 11:04 pm
chicago dating gay
free local gay sex dating
dating advice for gay guys
September 6, 2021 @ 11:21 am
buy methylprednisolone – medrol 4 mg coupon lyrica 150 mg coupon
September 7, 2021 @ 3:21 am
mature gay dating australia
gay dating ct
dating free gay in london
September 7, 2021 @ 12:13 pm
gay dad dating sims
gay dating sight
gay teen dating age gap
September 7, 2021 @ 3:41 pm
essay writing sites – good essay writers my friend essay writing
September 7, 2021 @ 7:53 pm
are there free gay dating aps
gay cum in my mouth dating now
gay dating events in nyc
gay dating sites omar mateen
September 8, 2021 @ 5:24 pm
gay online dating closeted https://gayonlinedating.net/
September 8, 2021 @ 11:45 pm
where to buy viagra in usa – Buy branded viagra buy viagra online in australia
gay positive dating
September 9, 2021 @ 1:49 am
gay chat
gay dating, inland empire, ca
September 9, 2021 @ 5:27 am
iceman dating gay https://dating-gaym.com/
September 10, 2021 @ 7:44 am
4467 cialis – Cialis mail order cialis 20mg coupon
September 10, 2021 @ 9:35 am
walmart gay dating ad
dating memphis gay
gay dating sioux city
gay speed dating boston ma
September 10, 2021 @ 6:16 pm
gay russian dating site https://datinggayservices.com/
gay dating phoenix k
September 11, 2021 @ 2:47 am
remeo gay dating https://gay-singles-dating.com/
September 12, 2021 @ 10:40 am
tips for online dating gay
is is barry jenkins dating gay
online gay dating site
September 12, 2021 @ 4:23 pm
stromectol 6 mg – buy ivermectin for humans uk ivermectin tablets order
September 12, 2021 @ 5:40 pm
dating advice for gay guys
monogamous gay dating
gay asian men dating black men
September 13, 2021 @ 5:28 pm
gay republican dating
free gay dating site in canada
indian gay dating site
September 13, 2021 @ 6:33 pm
prednisone 105mg – prednisolone prednisone prednisone pack
September 14, 2021 @ 11:59 pm
gay dating us
singer gay dating
gay dating in jellico tennessee
September 15, 2021 @ 12:14 am
price of lasix 80 mg – generic lasix 40 mg lasix 100 mg
September 15, 2021 @ 8:33 am
gay bareback dating
straight man dating gay man
gay hiv+ dating albuquerque nm
September 15, 2021 @ 3:37 pm
best gay dating sites 2021
megaphone gay dating
mateen used gay dating sites
September 16, 2021 @ 5:03 am
ventolin price canada – ipratropium albuterol ventolin 90
September 16, 2021 @ 3:25 pm
gay dating sites windows phone
gay dating greece
gay speed dating philadelphia
September 17, 2021 @ 10:26 am
where can i buy cytotec pills – buy generic cytotec cytotec cost in south africa
September 18, 2021 @ 7:16 pm
odering doxycycline – prednisolone over the counter australia buy prednisolone 5mg uk
September 19, 2021 @ 5:41 pm
https://stromectolo.com – stromectol
September 20, 2021 @ 2:27 am
buy ivermectin 2mg – ivermectin new zealand buy stromectol uk
September 21, 2021 @ 6:22 am
ivermectin 2% – ivermectin 6mg online buy ivermectin 3mg
September 22, 2021 @ 12:53 pm
sildenafil prescription – generic sildenafil names sildenafil 20
September 23, 2021 @ 7:10 pm
tadalafil citrate – buy tadalafil 20mg price tadalafil reviews
September 24, 2021 @ 10:51 pm
buy accutane online usa – accutane prescription discount how do i get accutane
September 26, 2021 @ 1:17 am
edit letter – help with papers websites to write essays
September 27, 2021 @ 7:14 am
price of ivermectin tablets – ivermectin pill cost ivermectin 3mg pill
situs gay dating
September 27, 2021 @ 2:16 pm
dating gay senior https://gayedating.com/
September 28, 2021 @ 11:15 am
department of health and human services lufkin texas http://levitrahims.com – levitra
September 28, 2021 @ 8:57 pm
can i buy real viagra online – lowest price on generic viagra how to buy generic cialis online
write a comparison essay
September 28, 2021 @ 10:27 pm
writing a persuasive essay https://essaywritercentral.com/
September 29, 2021 @ 12:12 am
lytx inc – http://allergyd.com
what to write about in a college essay
September 29, 2021 @ 11:04 am
what to write about for college essay https://essayghostwriter.com/
October 1, 2021 @ 1:58 am
buy vardenafil 10 mg – canadian pharmacy legit ed pills walmart
October 1, 2021 @ 9:30 am
levitra for sale – canadian pharmacy viagra reviews dr oz erectile dysfunction pills
October 2, 2021 @ 1:49 pm
hydroxychloroquine prescribing information – prednisone drug prednisone 2.5 mg tab
October 3, 2021 @ 5:49 pm
vidalista 60mg – cenforce 100 fildena 120mg
October 4, 2021 @ 8:29 pm
orlistat 60 mg precio – orlistat dosage instructions orlistat 60 mg preisvergleich
October 6, 2021 @ 6:14 am
ivermectin generic name – ivermectin lotion cost buy stromectol usa
October 7, 2021 @ 7:07 am
how to order sildenafil online – viagra mail order usa sildenafil 20 mg without a prescription
October 8, 2021 @ 9:11 am
36 hour cialis – cialis samples purchase cialis from canada
October 9, 2021 @ 5:20 pm
prednisone 40 mg – prednisone in uk prednisone 250
October 10, 2021 @ 2:57 pm
custom writing essay
jiskha homework help
October 11, 2021 @ 3:51 pm
buy cialis generic canada – tadalafil tablets cialis compare prices
pay someone to write your essay
October 11, 2021 @ 8:16 pm
writing a college essay https://essaysnet.com/
October 12, 2021 @ 1:11 pm
cheap viagra online usa supreme suppliers viagra
focus on writing paragraphs and essays
October 12, 2021 @ 3:23 pm
admission essay writing https://essaypoints.com/
October 12, 2021 @ 6:26 pm
ivermectin – stromectol nz buy stromectol online
writing narrative essay
October 13, 2021 @ 1:53 am
reflection essay on writing https://essaytag.com/
October 13, 2021 @ 9:40 pm
ivermectin 50 mg – ivermectin buy australia stromectol price in india
write that essay
October 14, 2021 @ 1:16 pm
best online essay writing services https://onlinecasinos4me.com/
best online essay writing services
October 14, 2021 @ 1:35 pm
write essay service https://online2casino.com/
October 14, 2021 @ 1:53 pm
levitra kaufen gГјnstig http://levitraoff.com levitra 20 mg film-coated tablets
October 14, 2021 @ 7:41 pm
write my research paper for me
executive resume writing services
October 15, 2021 @ 12:35 pm
buy viagra over the counter in australia – viagra female viagra buy online india
October 16, 2021 @ 5:39 pm
sildenafil 100mg cheap – female viagra pill how to get sildenafil prescription
October 17, 2021 @ 5:46 pm
cialis 1mg – cialis generic name cialis usa pharmacy
October 18, 2021 @ 7:26 pm
buy genuine cialis uk – Sales cialis 5 mg tadalafil coupon
October 18, 2021 @ 11:30 pm
levitra and penicillin http://www.levitraoff.com levitra maximum dosage
October 19, 2021 @ 11:59 pm
ivermectin 8000 mcg – stromectole online buy ivermectin
October 21, 2021 @ 9:17 am
ivermectin 12 mg over the counter – oral ivermectin cost ivermectin 9 mg
October 22, 2021 @ 6:54 am
viagra from europe supreme supplies in india viagra 100mg pills for sale
October 22, 2021 @ 8:25 am
cheap viagra for sale supremesuppliersmumbai.com
October 22, 2021 @ 10:34 am
casino slot – gambling casino best online casino for money
October 22, 2021 @ 8:20 pm
sky pharmacy online drugstore
October 23, 2021 @ 6:03 am
orlistat sky pharmacy
October 24, 2021 @ 12:06 am
buying a research paper for college – cheap dissertation help paper help
October 24, 2021 @ 4:56 am
canadian viagra supreme suppliers top rated generic viagra pharmacy