a. In the event a device is lost, stolen what happens? Whom does the patient and physician call to ensure PHI is protected and not accessed?
b. Clarity on where data is stored? Many of the companies bringing the technologies to bear are utilizing public cloud services for storage and retrieval of the data. This needs to be understood by both the medical facility and patient and what protections can and cannot be provided as a result of utilizing a service, e.g. Amazon cloud.
c. How does the patient and medical facility authenticate and verify access to PHI ?
d. Defining and designing security protections in medical health devices. Right now, in the limited instances we have viewed, the determination of what is enough security to protect patient data if not explicitly outlined in HIPAA or HITECH and is left to the developer. So there is a lack of standardization in how this is handled. In addition as many providers in this space are small business, it appears they are left to navigate cyber on their own with little background on what that means in a grander context of how a health insurer, hospital or physician office can or will support the security scheme if designed.
These are two key considerations for healthcare entities to manage mobile health solutions. Your technology and it's security is a critical part of the delivery of accurate and quality care to the patients you serve.