Disadvantages of Spreadsheets – Obstacles to Compliance in the Healthcare Industry

Most of the regulatory compliance issues we talked about concerning spreadsheets have been related to financial data. But there are other kinds of data that are stored in spreadsheets which may also cause regulatory problems in the future.

In the US, a legislation known as HIPAA or Health Insurance Portability and Accountability Act is changing the way health care establishments and practitioners handle patient records. The HIPAA Privacy Rule is aimed at protecting the privacy of individually identifiable health information a.k.a. protected health information (PHI).

Examples of PHI include common identifiers like a patient’s name, address, Social Security Number, and so on, which can be used to identify the patient. HIPAA covers a wide range of health care organisations and service providers, including: health plan payers, health care clearing houses, hospitals, doctors, dentists, etc.

To protect the confidentiality, integrity, and availability of PHI, covered entities are required to implement technical policies such as access controls, authentication, and audit controls. These can easily be implemented on server-based systems.

Sad to say, many health care organisations who have started storing data electronically still rely on spreadsheet-based systems. Those policies are hard to implement in spreadsheet-based systems, where files are handled by end-users who are overloaded with their main line of work (i.e. health care) and have very little concern for data security.

In some of these systems, spreadsheet files containing PHI may have multiple versions in different workstations. Chances are, none of these files have any access control or user authentication mechanism whatsoever. Thus, changes can easily be made without proper documentation as to who carried out the changes.

And because the files are normally easily accessible, unauthorised disclosures – whether done intentionally or accidentally – will always be a lingering threat. Remember that HIPAA covered entities who are caught disclosing PHI can be fined from $50,000 up to $500,000 plus jail time.

But that’s not all. Through the HITECH Act of 2009, business associates of covered entities will now have to comply with HIPAA standards as well. Business associates are those companies who are performing functions and services for covered entities.

Examples of business associates are accounting firms, law firms, consultants, and so on. They automatically need to comply with the standards the moment they too deal with PHI.

 

More Spreadsheet Blogs

 

Spreadsheet Risks in Banks

 

Top 10 Disadvantages of Spreadsheets

 

Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry

 

How Internal Auditors can win the War against Spreadsheet Fraud

 

Spreadsheet Reporting – No Room in your company in an age of Business Intelligence

 

Still looking for a Way to Consolidate Excel Spreadsheets?

 

Disadvantages of Spreadsheets

 

Spreadsheet woes – ill equipped for an Agile Business Environment

 

Spreadsheet Fraud

 

Spreadsheet Woes – Limited features for easy adoption of a control framework

 

Spreadsheet woes – Burden in SOX Compliance and other Regulations

 

Spreadsheet Risk Issues

 

Server Application Solutions – Don’t let Spreadsheets hold your Business back

 

Why Spreadsheets can send the pillars of Solvency II crashing down

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2015 ESOS Guidelines Chapter 3 ? The ESOS Assessment

ESOS operates in tandem with the ISO 50001 (Energy Management) system that encourages continual improvement in the efficient use of energy. Any UK enterprise qualifying for ESOS that has current ISO 50001 certification on the compliance date by an approved body (and that covers the entire UK corporate group) may present this as evidence of having completed its ESOS assessment. It does however still require board-level certification, following which it must notify the Environment Agency accordingly.

The Alternate ESOS Route

In the absence of an ISO 50001 energy management certificate addressing comprehensive energy use, a qualifying UK enterprise must:

  1. Measure Total Energy Consumption in either kWh or energy spend in pounds sterling, and across the entire operation including buildings, industrial processes and transport.
  2. Identify Areas of Significant Energy Consumption that account for at least 90% of the total. The balance falls into a de minimis group that is officially too trivial to merit consideration.
  3. Consider Available Routes to Compliance. These could include ISO 500001 part-certification, display energy certificates, green deal assessments, ESOS compliant energy audits, self-audits and independent assessments
  4. Do an Internal Review to make sure that you have covered every area of significant consumption. This is an important strategic step to avoid the possibility of failing to comply completely.
  5. Appoint an Approved Lead Assessor who may be internal or external to your enterprise, but must have ESOS approval. This person confirms you have met all ESOS requirements (unless you have no de minimis exceptions).
  6. Obtain Internal Certification by one of more board-level directors. They must certify they are satisfied with the veracity of the reports. They must also confirm that the enterprise is compliant with the scheme.
  7. Notify the Environment Agency of Compliance within the deadline using the online notification system at snapsurveys.com as soon as the enterprise believes is fully compliant.
  8. Assemble your ESOS Evidential Pack and back it up in a safe place. Remember, it is your responsibility to provide proof of the above. Unearthing evidence a year later it not something to look forward to.

The ESOS assessment process is largely self-regulatory, although there are checks and balances in place including lead assessor and board-level certifications. As you work through what may seem to be a nuisance remember the primary objectives. These are saving money and reducing carbon emissions. Contact Ecovaro if we can assist in any way.

Symbion Pharmacy Services? Definition of Responsibility

A ?symbion? is an organism in a symbiotic (i.e. mutually beneficial) relationship with another one. In the case of Australia?s giant Symbion Pharmacy Services, this means supplying and delivering over-counter Chemmart medicines to more than 3,000 hospital and retail pharmacies, while remaining mindful of its carbon footprint.

In 1999, the company with the tagline ?life matters? and a desire to be seen as ?a good corporate citizen? decided it was time to measure exactly what it was pumping out from 12 facilities and over 200 vehicles. This was a voluntary decision as even now there is still no carbon emissions law in Australia (although no doubt being a ?first mover? will put the company in a competitive position when this inevitably comes).

Symbion decided to install emission detection devices and connect these to a central monitoring system with the intention of managing what these measured. There were two stages to this process. First, Symbion determined its reporting requirements based on one of its larger warehouses. Following that, it established a carbon footprint for each of its wholly owned and managed facilities. This put it in a position to:

  • Analyse total emissions down to a level of detail where it understood the contribution of each source
  • Use big data management tools to identify carbon hotspots for priority remedial action
  • Inform the affected workforce, explain the monitoring system and keep them in the loop
  • Separately manage energy abatement programs such as lighting and delivery routes

The program also had productivity spin-offs in that it focused management attention on the processes behind the emissions that were ripe for material and system improvements. It also provided marketing leverage. Symbion?s customers are in the wellness business, ahead of the curve when it comes to how emissions contribute to chronic illness, and aware of the cost of this in terms of human capital.

EcoVaro could help you manage your throughputs by analysing your data on our cloud-based system. This includes trending your metrics, comparing them to your industry seasonal average, and providing you with a business-like view of how well you are doing.

Our service reduces your reliance on (and the cost of) third party audits, and simplifies the reporting process to your controlling authority. It simply makes more sense to contract your software out this way, and only pay for it when you need it.

8 Best Practices To Reduce Technical Debt

When past actions in software development return to haunt you…

Is your business being bogged down by technical debt? Let’s look at measures that you can take to reduce it and scale your operations without the weight pulling you back. 

 

Work with a flexible architecture.

Right from the word go, you want to use architecture whose design is malleable, especially with the rapid rate of software evolution witnessed today. Going with an architecture that keeps calling for too much refactoring, or whose design won’t accommodate future changes will leave you with costly technical debt. Use scalable architecture that allows you to modify or add new features in future releases. While on this, complex features required in the final product should be discussed at the planning stage, that way simplified solutions that will be easier to implement can be identified, as this will lead to less technical debt in the long run. 

 

The Deal with Refactoring 

This is basically cleaning up the code structure without changing its behaviour. With the updates, patches, and new functionalities that are added to the systems and applications, each change comes with the threat of more technical debt. Additionally, organisations are increasingly moving their IT infrastructure from on-premises facilities to colocation data centres and deploying them on the cloud. In such scenarios, some workarounds are often needed to enable the systems to function in the new environments, which they hadn’t been initially developed to accommodate. Here, you will need to take some time to refactor the existing system regularly, streamlining the code and optimizing its performance – and this will be key to pay down the tech debt. When working with a flexible architecture from the start, the amount of work that goes into this will be reduced, meaning there’ll be less tech debt involved. 

 

Run discovery tests

Discovery testing essentially takes place even before a line of code is written for the system or application. This takes place at the product definition stage, where human insight software is used to understand the needs of the customer and is particularly helpful in setting priorities for the development work that will be carried out. It gives your business the opportunity to minimize the technical debt by allowing customers to give you a roadmap of the most pertinent features desired from the product. 

 

Routine code review

Getting a fresh look at the product or application from different sets of eyes in the development team will improve the quality of the code, thus reducing technical debt. There’s a catch though – this should be planned in a convenient way that doesn’t end up becoming a burden for the developers. Here are suggestions:

Break down pull requests

Instead of having complex pull requests where numerous changes in the code are introduced at a go, have this broken down into smaller manageable pull requests, each with a brief title and description about it. This will be easier for the code reviewer to analyse. 

● Define preferred coding practices

Documenting the preferred coding style will result in cleaner code, meaning the developers will focus their effort on reviewing the code itself, not losing time on code format debates.

 

Test automation

Relying only on scheduled manual testing opens you up to the risk of technical debt accruing rapidly, and not having sufficient resources to deal with the accumulated problems when they are identified. Automated testing on the other hand enables issues to be uncovered quicker, and with more precision. For instance, you can have automated unit tests that look at the functioning of the individual components of a system, or regression testing where the focus is on whether the code changes that have been implemented have affected related components of the system. However, establishing and maintaining automated testing will require quite some effort – making it more feasible for the long-term projects.

 

Keep a repository that tracks changes made

Do you have a record of changes made in the software? Keeping one in a repository that is accessible by the development team will make it easy to pin-point problems at their source. For instance, when software is being migrated to a new environment, or legacy software is in the process of being modernised, you will want to have an accurate record of changes that are being introduced, that way if there is an undesired impact on the system this it will be easier to zero-down on the cause.

 

Bring non-technical stakeholders on board

Does this conversation sound familiar?

Development Team: “We need to refactor the messy code quickly”

Product Team: “We have no idea what you are saying”

On one hand, you have the management or product team defining the product requirements, creating a project roadmap, and setting its milestones. On the other hand, there’s the software development/engineering that’s primarily focused on the product functionality, technical operations and clearing the backlog in code fixes. Poor communication between the two teams is actually a leading cause of technical debt.

For you to take concrete steps in managing your technical debt, the decision-makers in the organisation should understand its significance, and the necessity of reducing it. Explain to them how the debt occurred and why steps need to be taken to pay it down – but you can’t just bombard them with tech phrases and expect them to follow your thought process. 

So how do you go about it? Reframe the issues involved with the technical debt and explain the business value or impact of the code changes. Basically, the development team should approach it from a business point of view, and educate the management or production team about the cost of the technical debt. This can include aspects such as expenses in changing the code, salaries for the software engineers especially when the development team will need to be increased due to the workload piling up, as well as the revenue that is lost when the technical debt is allowed to spiral. 

The goal here is to show the management or production team how issues like failing to properly define the product requirements will slow down future software development, or how rushing the code will affect the next releases. That way, there will be better collaboration between the teams involved in the project. 

 

Allocate time and resources specifically for reducing technical debt

With management understanding that working with low-quality code is just like incurring financial debt and it will slow down product development, insist on setting time to deal with the debt. 

For instance, when it comes to the timing of application releases, meetings can be conducted to review short- and longer-term priorities. These meetings – where the development team and product team or management are brought together, the developers point out the software issues that should be resolved as a priority as they may create more technical debt. Management then ensures that budgets and plans are put in place to explicitly deal with those ongoing maintenance costs.

 

Retire old platforms

While most of the resources are going into developing new applications and improving the systems being used, the organisation should also focus on retiring the old applications, libraries, platforms, and the code modules. It’s recommended that you factor this into the application release plans, complete with the dates, processes and costs for the systems involved. 

 

Total overhaul

When the cost and effort of dealing with the technical debt far outweighs the benefits, then you may have to replace the entire system. At this tipping point, you’re not getting value from the technical debt, and it has become a painful issue that’s causing your organisation lots of difficulties. For instance, you may be dealing with legacy software where fixing it to support future developments has simply become too complicated. The patches available may only resolve specific issues with the system, and still leave you with lots of technical debt. Here, the best way out is to replace the system in its entirety. 

 

Final thoughts

Every software company has some level of tech debt. Just like financial debt, it is useful when properly managed, and a problem when ignored or allowed to spiral out of control. It’s a tradeoff between design/development actions and business goals. By taking measures to pay down your organization’s debt and address its interest as it accrues, you will avoid situations where short term solutions undermine your long-term goals. This is also key to enable your business to transition to using complex IT solutions easier, and even make the migration between data centres much smoother. These 8 measures will enable you to manage your technical debt better to prevent it from being the bottleneck that stifles your growth.

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