09-17-13 | Blog Post

Attn, Healthcare Industry: SAS 70 is No Zombie

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Although SAS 70 (Statement on Auditing Standards) has been dead for quite some time now, we’ve found that those lagging in the health IT industry may still be confused about why SAS 70 is no longer the audit to look for when it comes to ensuring security with a cloud hosting provider. In fact, false information about SAS 70 as a qualifier for cloud computing security supporting the healthcare industry is still an issue.

Some suggest that SAS 70 is comparable to a HIPAA audit because they both check for an organization’s security controls. However, SAS 70 was never designed to measure data center security, but instead to measure internal controls related to financial reporting.

As major research firm Gartner stated, “SAS 70 is being misused by many vendors, and often their customers and certified public accountants (CPAs), in the hosted-application, software as a service (SaaS) and cloud computing spaces.”

So what’s better than SAS 70? Some say SSAE 16 (Statement on Standards for Attestation Engagements), which replaced the standard in 2011. But even an SSAE 16 report only reports on controls related to financial reporting, and not on controls directly related to data center privacy, security and availability.

Here’s where a SOC 2 (Service Organization Control) audit report comes in to save the day and confirm that your service provider has all of the best internal practices in place for these five controls: Security, Availability, Processing Integrity, Confidentiality and Privacy. Why choose a SOC 2 report over SOC 3? A SOC 2 report is more detailed, and affects companies that host or store large amounts of data, such as cloud hosting and data center operators.

So a SOC 2 report may suffice for most seeking an audit report that most accurately reflects a cloud hosting provider’s internal security controls. But for those in the healthcare industry dealing with patient data, there’s one step even further to ensure security with cloud hosting providers.

Look for a HIPAA compliant hosting provider that has a third-party independent audit report of their company’s controls against the OCR (Office for Civil Rights) HIPAA Audit Protocol. Ask them which requirements they can fulfill to satisfy the IT side of the HIPAA standards.

On the administrative side, ask them if and when they last completed HIPAA staff training as a business associate, and whether or not they will sign a business associate agreement (BAA) clarifying their role and responsibilities when it comes to your data security. This HIPAA Compliant Hosting white paper explains the IT infrastructure and administrative sides completely.

SAS 70 is so dead. And definitely needs to be laid to rest. Don’t let it become an audit zombie. Just let it go and embrace the future of SOC 2 and independent HIPAA audits.

Update: SAS 70 reports only on controls related to financial reporting. If you need assurance of controls directly related to data centers, including privacy, security and availability, look for a SOC 2 report.
SAS 70 was replaced by SSAE 16 in June 2011.

Gartner Says SAS 70 Is Not Proof of Security, Continuity or Privacy Compliance

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