Recovering from a cyber incident, responding to the OCR, and building a cyber resilient posture for the future

A conversation with OrthoVirginia CIO, Terri Ripley

“It was that Swiss cheese effect; the gaps all lined up perfectly,” says Terri Ripley, CIO of OrthoVirginia, describing the perfect storm that made it possible for a cyberattacker to break into their network amid the COVID-19 pandemic. While the incident itself took place in 2021, resolution with the OCR was just reached in the last month.

The physician-owned network of more than 130 orthopedic specialists had just ramped surgeries back up after canceling them during the worst of the pandemic. It wasn’t long after that a phishing email made for the perfect exploit, giving a cyberattacker the opportunity to encrypt their PACS images and hold them hostage to ransomware.

Ripley, a healthcare veteran and experienced executive, and her team had worked hard to stay current on all the cybersecurity requirements. Still, they struggled to get some things, like multi-factor authentication, in place. After two attempts, issues with the technology created workflow barriers, so they paused the initiative. “Honestly, we thought we were too small to be a target,” said Ripley.

And then COVID hit. OrthoVirginia sent all their non-clinical personnel home to keep them safe, protect their patients, and protect their doctors so they could continue providing care. Ripley says they knew there were risks to this decision, but they needed to act quickly, and they chose to mitigate the spread of COVID as a first priority. In hindsight, Ripley says they simply weren’t prepared to have their workforce safely access their systems remotely.

Finding an expert

As CIO, Ripley owned the organization’s cybersecurity strategy and said she knew quickly upon the cyber incident that they needed outside help to recover and prevent something similar from happening again.

Beginning with KLAS research, Ripley looked up top performers and selected three to request proposals. “It was really important to us that we partner with someone who really knew healthcare and that would listen to us,” Ripley told us. Protective of her team, she acknowledged mistakes were made but felt it was also important they didn’t lose sight of the gravity of the pandemic. She wanted a vendor ready to get in the trenches with them and help them solve real challenges, not pass judgment. Though OrthoVirginia initially set out to find a virtual chief information security officer (vCISO), they eventually expanded the scope to include help with their risk analysis and overall strategy.

ClearAdvantage was the right fit

Ripley says she selected Clearwater’s ClearAdvantage® managed services program for Clearwater’s expertise in healthcare cybersecurity and compliance, experience with the Office for Civil Rights (OCR), and overall partnership approach. ClearAdvantage delivers organizations like OrthoVirginia cybersecurity and compliance best practices, like risk analysis and vulnerability assessments, program leadership, like a vCISO, and on-demand access to cybersecurity experts all in one cost-effective program.

Clearwater worked with Ripley and her team to do an OCR-Quality® Risk Analysis, something Ripley says was different than previous risk analysis initiatives. “We had done risk assessments before, but Clearwater’s approach was rigorous and complete, it gave us more actions we could take to mitigate risk and better oversight to make sure those improvements were getting made.”

Since then, OrthoVirginia has successfully implemented multi-factor authentication, the use of digital identity badges, and added components like a Cybersecurity Program Performance Assessment, technical testing, and executive tabletop exercises to their cybersecurity strategy.

Not in the clear, yet

Though OrthoVirginia had made several changes to bolster its cybersecurity strategy, it received a letter from the OCR approximately eight months after the original attack.

A patient tried to access their x-ray results and, after being delayed, filed a complaint with the OCR. Ripley says they panicked at first but knew Clearwater had extensive experience with the OCR and could help them respond. OCR issued OrthoVirginia a corrective action plan that would have cost them millions of dollars to implement. After consulting with their forensic attorneys and Clearwater, Ripley respectfully appealed the corrective action plan.

“It was scary,” Ripley explained, “but the Clearwater team had experience here, too, and helped us articulate in a very transparent way what we had in place and how we were following the requirements of the HIPAA Security Rule. As a result, the OCR agreed that the corrective action plan wasn’t needed.”

Confidence for the future

With a robust strategy in place and a partner to help navigate new and emerging threats, Ripley says, “I sleep better at night. We’re so busy getting things done that we need someone in our corner to make sure we’re keeping up, measuring how we’re doing against our scorecard, and ultimately giving us the confidence that we won’t have to live through that nightmare again. If something does happen, we’ll know we’ve done everything we can to prevent it.”

Ripley says that having a partner like Clearwater also means they are more aware of what’s happening outside their organization. She says there’s a lot of value in having a partner who can help OrthoVirginia leverage lessons learned in other organizations and prevent some of the things others have also had to learn the hard way.

Sharing experiences and lessons learned

Ripley has shared her story in multiple forums, including the HIMSS Virginia Chapter and CHIME Fall Forum in 2022, hoping others can benefit from what OrthoVirginia has learned from their cyberattack and recovery.

Her advice for others?

“Make sure you partner with someone who has the right experience. For us, that means healthcare experience and OCR experience-they need to know what cyber threats could affect our organization, how to protect us from them, and the right approach to usher us through it. You can’t know it all yourself; finding an expert focused on cybersecurity and compliance in healthcare to be your partner is so critical.”

About OrthoVirginia

OrthoVirginia is Virginia’s largest provider of expert orthopedic and therapy care which serves the needs of its patients through a team of highly trained specialists who are committed to the independent practice of medicine. Located in Hampton Roads, Lynchburg, Northern Virginia, Richmond, and Southwest Virginia, OrthoVirginia has more than 130 physicians and over 30 office locations, orthopedic urgent cares, MRI facilities, outpatient surgery centers and physical therapy clinics. Virginia Orthopedics | OrthoVirginia: Stronger Starts Here OrthoVirginia combines science, technology, and a creative approach to deliver Virginia’s premier orthopedic, physical therapy, and sports medicine care.

About Clearwater

Clearwater, together with its CynergisTek subsidiary and TECH LOCK Division, helps organizations across the healthcare ecosystem move to a more secure, compliant, and resilient state so they can successfully accomplish their missions. We do this by providing a deep pool of experts across a broad range of cybersecurity, privacy, and compliance domains, purpose-built software that enables efficient identification and management of cybersecurity and compliance risks, and a tech-enabled, 24x7x365 Security Operations Center with managed threat detection and response capabilities. To learn more, please visit www.clearwatersecurity.com.

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