Connectivity and Hackability

Connectivity and Hackability

It is somewhat ironic that Hospira and Cerner announced a new collaboration on Hospira’s infusion pumps and Cerner’s EHR given that Hospira has recently had more than its share of attention with respect to asserted LifeCare and Symbiq pump cybersecurity vulnerabilities. This attention included a notice from the Department of Homeland Security as well as from the FDA (here and here). I found it of interest that despite the widespread hype around these notices there has been no recall of these pumps for the related issues. Instead advice was given to transition away from their use, mitigate the risks by some technical changes, and await Hospira’s updates.

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Some Funky Cybersecurity Math

Some Funky Cybersecurity Math

Assessing the magnitude and significance of cyber threats has at least two important purposes. One is to determine the extent of measures that have been or should be taken to respond to or counter the threat. This is part of the rational deployment of resources across the multiple risks that we face, whether cyber or otherwise. In this regard it is simply not possible or necessary to respond to all risks with equal vigor. A second purpose can be to communicate threat significance to or among interested parties. For such communication there is a tendency to reduce complex, multifaceted issues to a simple broad summary word, e.g., the threat level is “Guarded”. Such simplicity is possibly attractive but not necessarily meaningful with regard to what to do with the information communicated.

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The FDA October Workshop on Cybersecurity

The FDA October Workshop on Cybersecurity

If it were possible to be unaware of the general problem  of cybersecurity, the recent Sony hack with its public disclosures of  “private” e- conversations and then terroristic blackmail, following the earlier release of celebrity cloud photos, ought to have provided notice that what is electronically stored is likely to be available to those determined to have it. Moreover we know that cybersecurity can in principle also impact the function and availability  of connected systems (Sony again) and/or the information they contain. We also need to be concerned about the malicious alteration of information or disruption of device performance. You may remember the hacked insulin pump story which is already a few years old, and the story that the wireless function of Vice President Cheney’s pacemaker was disabled to protect against hacking.

In this broad context it may be worth taking a look at the FDA’s  now posted contents of the October 21-22, 2014 FDA workshop on  “Collaborative Approaches for Medical Device and Healthcare Cybersecurity”. There is also a link there to the October 29 FDA Webinar on the Final Guidance on Premarket Submissions for Management of Cybersecurity in Medical Devices.  (If that link doesn’t work, as it didn’t for me, try here.) I had not been not aware that October was National Cybersecurity Awareness Month under the auspices of the Department of Homeland Security (DHS).

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DHHS OIG Work Plan Targets Networked Devices

DHHS OIG Work Plan Targets Networked Devices

The Office of the Inspector General (OIG) of the U.S Department of Health and Human Services has released a report (pdf) outlining its 2015 work plan.  Among a host of subjects is “Information Technology Security, Protected Health Information, and Data Accuracy” with the subsection “Controls over networked medical devices at hospitals”. The focus here is on the security of  patient electronic health information which is to be protected under law. Other risks associated with device networking are not addressed.

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A Medical Device Recall of an EHR-like Product

A Medical Device Recall of an EHR-like Product

The recent recall (links below) for McKesson’s Anesthesia Care system raises interesting questions about potential information system failure modes as well as what system/software functions cross the imaginary line between unregulated EHRs and regulated medical devices.

First the facts. The FDA announced McKesson’s voluntary recall of its Anesthesia Care system in several on-line (here, here and here)  postings. This trio of postings is interesting because the first links only to the second, the second does not link to either of the other two. The third also does not link to the other two, and was not part of any of the announcements, but it is the most complete.

The statement of the reason for the recall is that, “There was an occurrence where the patient case data did not match the patient data when the case was recalled in the anesthesia care record (ACR) in that it included data from another case.” It was further noted that, “Use of this affected product may cause serious adverse health consequences, including death.”  In the third link the FDA identifies the product as,

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