Operating as a Hybrid Entity at Cornell John Ruffing – [email protected]@cornell.edu Assistant Director, Center for Advanced Computing (CAC) Cornell.

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Operating as a Hybrid Entity at Cornell

John Ruffing – [email protected] Director, Center for Advanced Computing (CAC)

Cornell University

Associate Director, Information Technology and Services

Weill Cornell Medical College

www.cac.cornell.edu

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Overview

• Informing Perspectives• Organizational “Objects”• Cornell Logistics

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Perspectives

• Institutional• Individual

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Perspectives: Institutional

• Medical campus• Significant separation

–Distance, governance, ERP• Burdens

–Extensive–Expensive (potentially)

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Burdens: Extensive

• Executing– Administrative– Technical– Physical

• Maintaining– Documentation– Training/Awareness– Periodic Review

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Perspective: Individual

• Medical campus• Previously led

–EHR implementation (Epic)–SAP technical teams

• Coordinate IT aspects of audit

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Overview

• Informing Perspectives• Organizational “Objects”• Cornell Logistics

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Organizational Objects

• Covered Entity• Organized Healthcare Arrangement• Business Associate

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Covered Entities

www.cac.cornell.edu

• Health Plans• Healthcare Clearinghouses• Healthcare Providers who

–Electronically transmit• Any health information in connection

with–Transactions for which HHS has

adopted standards

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Typical HPC Providers

www.cac.cornell.edu

• Not covered entities themselves

• Not part of covered entity• Handling identifiable data

–Within the same institution–Ultimately from a covered

entity

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Covered Entity Trap

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• Entire legal entity–Often more than really applies

• Unnecessary burden–Extent–Expense

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Hybrid Entity Escape?

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• Covered components–Same criteria as entity–Distinct and relevant

•Function•Governance

• Formal designation

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Cornell as Hybrid Entity

www.cac.cornell.edu

• Four components–Medical campus–Student health center–Benefits–Counsel

• Where is HPC?

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Typical HPC Providers

www.cac.cornell.edu

• Not covered components themselves

• Not part of covered component• Resistance to including

–Burden–Definition

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Business Associate

www.cac.cornell.edu

• Relationship to covered entity–For or on behalf–Other than in the workforce

• Separate legal entity

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Overview

• Informing Perspectives• Organizational “Objects”• Cornell Logistics

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Where is HPC?

• Privacy Rule–Extend the workforce

• Security Rule–Extend the protections

• Only as needed

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Including HPC at Cornell

• Reminder: medical campus perspective

• Extending walled garden–Potential savings

• Not yet trying to share full resources• Three aspects

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Including HPC: Physical

• Co-lo–Already has personnel controlling and

logging–Rationale for remote location

• Separate racks–Separate keys and associated controls

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Extending to HPC: Technical

• IP Network– Extension of med network into data center

• With all security trimmings– Air gap (garden wall) to other networks

• Storage– Separate physical disks

• Shared array, on private management network– Shared storage switch

• Separate when volume makes feasible

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Extending to HPC: Administrative Sharing

• Workforce– The lesson of athletics– Sysadmins leverage med training and

awareness, follow documentation and procedures– Joint position supervision (direct control)

• Compliance– Elements accountable within garden

• E.g. shared array, on private management network– Other frameworks and HITRUST