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Bright Day Wellness Center (BDWC) Case StudyBackground: Bright Day Wellness Center (BDWC) is a health and wellness facility with one location in the San Diego California area. The facility offers the following services: License chiropractic visits, licensed physical therapy visits, licensed massage therapy services and yoga instruction. The facility is licensed to operate as a provider within the state of California and provider staff such as the chiropractors, physical therapist and massage therapist are currently licensed professionals in their fields. In terms of information technology platforms, the center uses a claims and billing application called Pronto to collect and store insurance information for clients and submit claims for billable services. The system runs online through computers at the wellness center. Physical therapist also used a secure online system called PT FIMS which is a clinical information system that automatically calculates functional independence measure her scores for PT clients allowing compliant billing for physical therapy services. Clinical documentation is done manually and paper charts that are stored in file drawers in various locations throughout the center. BDWC has a website. Currently the website is not used as an interactive tour but a passive web page with information about the center. There are testimonials and deidentified images on the website for marketing purposes. Current Challenge/Opportunity Scenarios: Scheduling: the clinical leaders and board of trustees who govern the wellness center would like to investigate moving toward a secure online scheduling application for used by both clients and internal staff. There is a perception that there is a great deal of inefficiency and confusion with regard to clinical scheduling. This is especially true of billable services such as physical therapy and chiropractic visits. There is a local technology company (the company who runs the wellness center website) called Technology Zoom who has offered to develop a customized scheduling application for BDWC. Biometrics: Recently the lead physical therapist attended a conference and developed a low- cost deal with a vendor who provides PT biometric tracking activity devices for clients who require intensive physical therapy. The PT director at BDWC obtained five of these devices and allocated these devices to his most active current physical therapy patients. The devices were put on the BDWC network so that the physical therapist could see client data uploads on a real time basis from the devices through wireless connectivity. IP addresses for these pilot testing devices were provided remotely by a technician at the Technology Zoom company who maintains the BDWC network. BDWC Volume Information: 6000 billable client visits per year about 1/3 PT and the reminder chiropractic 750 massage appointments per year 350 Yoga clients IT Scheduling Solutions: Financial Information: A local information technology development company called Technology Zoom Inc. has offered to develop the clinical scheduling platform for BDWC. • Cost of programming $85.00/hour • Cost of analyst time $85.00/hour • Cost of project manager time $110.00/hour • Estimates for end user requirements gathering time required of PTs, office staff and chiropractors is 200 hours • Programming time is unknown until requirements are completed and signed off. • Recent occupational therapy office scheduling application was 300 programming hours and 200 analyst hours to develop. In terms of investigating other purchased software options for client scheduling, the manager of the DWC has been meeting with sales representatives from a software as a service company such as Luma Health and others. Based on current volumes for physical therapy and chiropractic appointments, Luna helper has submitted a preliminary bed determining that they could run the BWC physical therapy and chiropractic appointments on a secured software as a service cloud basis through their application for $15,000 per month. This fee includes all maintenance and upgrades and reporting for the software once it is up and running. The initial fee to get the clinic up and running and configured on the software is estimated to be approximately $35,000 in consultative and end-user training fees. Bright Day Wellness Center ePHI Inventory Definition: Office/Site Laptop Computers or other Devices Containing ePHI including medical devices used for treatment, printers, barcode scanners etc. Inventory Number What is This Device (Computer, Laptop, Tablet, Kiosk, Printer, Scanner, Phone, Medical Device) Asset Tag Number Serial Number Device Location Device Owner Site Location Networked Device Y/N If Y, IP Address Operating System Version Description of ePHI on This Device Hard Drive Encrypted Y/N or (U) Unsure Example Laptop 45-777-9098 4546454647848HJ6767 virtual/Marcy’s office Marcy Jones (scheduler) BrightDay Office 2002 Carmen Drive San Diego CA 91977 Y 178 145 56 124 Windows 10 client lists with demographics, payment informatio and reason for visits Y 1 Smart phone unknown 33433344466 virtual Dr. Bob Jones (Chiropractor) virtual Y unknown Iphone 7s (IOS version unknown) list of clinical trial clients for drug trial Y (encrypted by consultant 2 years ago, not sure about updates to encryption software) 2 Desktop Computer 45-777-9093 8546434645848HJ6767 Site front desk Janet Smith (Center Manager) BrightDay Office 2002 Carmen Drive San Diego CA 91977 Y 178 145 56 119 Windows 10 online ePHI applications and folders on hard drive with client scanned letters and notes from providers Y (encrypted by consultant 2 years ago, not sure about updates to encryption software) 3 Desktop Computer 45-777-9094 7546734647748HJ6767 Site procedure room Janet Smith (Center Manager) BrightDay Office 2002 Carmen Drive San Diego CA 91977 Y 178 145 56 117 Windows 10 online ePHI applications and folders on hard drive with client scanned letters and notes from providers Y (encrypted by consultant 2 years ago, not sure about updates to encryption software) 4 Desktop Computer 45-777-9095 7955934647748HJ6767 Site procedure room Janet Smith (Center Manager) BrightDay Office 2002 Carmen Drive San Diego CA 91977 Y 178 145 56 115 Windows 10 online ePHI applications and folders on hard drive with client scanned letters and notes from providers Y (encrypted by consultant 2 years ago, not sure about updates to encryption software) 5 Printer 45-777-9082 HP7745623J Site front desk Janet Smith (Center Manager) BrightDay Office 2002 Carmen Drive San Diego CA 91977 Y 178145 56 114 HP OS 12.3.45 ePHI reports, notes and client letters printed to this device U 6 PT biometric PT Activity Trackers (5) devices provided to 5 physical therapy clients as a pilot 45-777-9097 unknown with pilot clients virtual PT supervisor Ned Willis BrightDay Office 2002 Carmen Drive San Diego CA 91977 Y Four IP addresses assigned to network: 178145 56 120, 178145 56 121, 178145 56 122, 178145 56 123 unsure client name, demographics and FIMS scores as well as pain scale results U Definition: Business platforms and computer applications used for both clinical care and administration. Inventory Number Name of System Purpose of System Vendor (if known) Vendor Contact Information Type(s) of User (s) e.g. Clinicians, administration, patients Number of Users (if Known) Mobile Access to this System (Y/N) Home Computer Access to this System (Y/N Type of ePHI in this System Example Billing communicate with patients, researchers etc Cadence Billing Inc. MS rep Rob Caggiano 412 855 5333 clinicians, administrators 5 N N Billing and insurance and claims information for clients 1 Pronto Claims Processing File insurance claims and gain authorizations Navinet rep Jane Curry 1685 North Parkway Pittsburgh PA 15222 manager 2 N N Billing and insurance and claims information for clients 2 PT FIMS Functional Independence Measure scoring for PTs Cerner rep Margaret Sales 3 physical therapists with log ins plus manager 4 Y Y client diagnoses and clinical notes Analyze the electronic protected health information (ePHI) inventory collected by the BDWC staff, including all line items recorded in each workbook (devices, online systems, and other ePHI locations). List the high-risk line items based on the reading and the Office of National Coordinator required resources. Critique the risk specific to the addition of physical therapy activity tracker biometric devices. Analyze feasible technical, operational, and financial resources and actions needed to mitigate identified security risks. Formulate a call-to-action statement summarizing the most significant risks for the board of trustees’ attention. Please put answers into essay form

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