Challenges for protecting the privacy of health information: required certification can leave common vulnerabilities undetected

The use of electronic health record (EHR) systems by medical professionals enables the electronic exchange of patient data, yielding cost and quality of care benefits. The United States American Recovery and Reinvestment Act (ARRA) of 2009 provides up to $34 billion for meaningful use of certified EHR systems. But, will these certified EHR systems provide the infrastructure for secure patient data exchange? As a window into the ability of current and emerging certification criteria to expose security vulnerabilities, we performed exploratory security analysis on a proprietary and an open source EHR. We were able to exploit a range of common code-level and design-level vulnerabilities. These common vulnerabilities would have remained undetected by the 2011 security certification test scripts from the Certification Commission for Health Information Technology, the most widely used certification process for EHR systems. The consequences of these exploits included, but were not limited to: exposing all users' login information, the ability of any user to view or edit health records for any patient, and creating a denial of service for all users. Based upon our results, we suggest that an enhanced set of security test scripts be used as entry criteria to the EHR certification process. Before certification bodies spend the time to certify that an EHR application is functionally complete, they should have confidence that the software system meets a basic level of security competence.