If you are a medical practice, you should have a HIPAA security assessment done on a yearly basis.  You also need to review your HIPAA policy and procedure manual on a regular basis.   In that manual is a password management policy number 164.308(a)(5)(ii)(D).  This is the policy that spells out how you need to handle the passwords in your network.  Don’t ignore your password policy.  It is one of the most important parts of network security and you don’t want to be caught using a bad password.

Passwords Are Inconvenient

I can’t tell you how many times I hear how inconvenient it is to use strong passwords and to follow the password policy.  “I don’t remember it” said one of my customers.  “I don’t have time to guess my password or reset it.  Plus, it locks me out.”  Let me put it to you this way…EVERYONE has trouble remembering passwords. That’s why applications such as Lastpass and Dashlane exist.  They are password vaults that you can use to store your passwords.

Don’t Ignore Your Password Policy

Putting a good policy in place is half the battle.  Administering it and getting you staff to adhere to it is the other half.  Below is a “soup starter” for a decent password policy you can implement in your practice.

Password Policy

The scope of this policy includes all personnel who have or are responsible for an account (or any form of access that supports or requires a password) on any system that resides at any <PRACTICE NAME> facility, has access to the <PRACTICE NAME>network, or stores any non-public <PRACTICE NAME> information.

1.0 Policy

1.1 General

  • All system-level passwords (e.g., root, enable, Windows/Unix/Aix/Linux admin, application administration accounts, etc.) must be changed on at least a quarterly basis.
  • All production system-level passwords must be part of the <PRACTICE NAME>administered global password management database.
  • All user-level passwords (e.g., email, web, desktop computer, etc.) must be changed at least every six months. The recommended change interval is every four months.
  • User accounts that have system-level privileges granted through group memberships or programs such as “sudo” must have a unique password from all other accounts held by that user.
  • Passwords must not be inserted into email messages or other forms of electronic communication.
  • Where SNMP is used, the community strings must be defined as something other than the standard defaults of “public,” “private” and “system” and must be different from the passwords used to log in interactively. A keyed hash must be used where available (e.g., SNMPv2).
  • All user-level and system-level passwords must conform to the guidelines described below.


1.2 Guidelines

  1. General Password Construction Guidelines

Passwords are used for various purposes at <PRACTICE NAME>. Some of the more common uses include: user level accounts, web accounts, email accounts, screen saver protection, voicemail password, and local router logins. Since very few systems have support for one-time tokens (i.e., dynamic passwords which are only used once), everyone should be aware of how to select strong passwords.

Poor, weak passwords have the following characteristics:

  • The password contains less than eight characters
  • The password is a word found in a dictionary (English or foreign)
  • The password is a common usage word such as:
    • Names of family, pets, friends, co-workers, fantasy characters, etc.
    • Computer terms and names, commands, sites, companies, hardware, software.
    • Birthdays and other personal information such as addresses and phone numbers.
    • Word or number patterns like aaabbb, qwerty, zyxwvuts, 123321, etc.
    • Any of the above spelled backwards.
    • Any of the above preceded or followed by a digit (e.g., secret1, 1secret)

Strong passwords have the following characteristics:

  • Contain both upper and lower case characters (e.g., a-z, A-Z)
  • Have digits and punctuation characters as well as letters e.g., 0-9, !@#$%^&*()_+|~-=\`{}[]:”;'<>?,./)
  • Are at least eight alphanumeric characters long.
  • Are not a word in any language, slang, dialect, jargon, etc.
  • Are not based on personal information, names of family, etc.
  • Passwords should never be written down or stored on-line. Try to create passwords that can be easily remembered. One way to do this is create a password based on a song title, affirmation, or other phrase. For example, the phrase might be: “This May Be One Way To Remember” and the password could be: “TmB1w2R!” or “Tmb1W>r~” or some other variation.

NOTE: Do not use either of these examples as passwords!

  1. Password Protection Standards

Do not use the same password for <PRACTICE NAME> accounts as for other non-<PRACTICE NAME> access (e.g., personal ISP account, option trading, benefits, etc.). Where possible, don’t use the same password for various <PRACTICE NAME> access needs. For example, select one password for the Engineering systems and a separate password for IT systems. Also, select a separate password to be used for Windows account and a UNIX account.

Do not share passwords with anyone, including administrative assistants or secretaries. All passwords are to be treated as sensitive, Confidential <PRACTICE NAME> information.

Here is a list of “don’ts”:

  • Don’t reveal a password over the phone to ANYONE
  • Don’t reveal a password in an email message
  • Don’t reveal a password to the boss
  • Don’t talk about a password in front of others
  • Don’t hint at the format of a password (e.g., “my family name”)
  • Don’t reveal a password on questionnaires or security forms
  • Don’t share a password with family members
  • Don’t reveal a password to co-workers while on vacation

If someone demands a password, refer them to this document or have them call someone in the Information Security Department.

Do not use the “Remember Password” feature of applications  (e.g., PM/EMR, Web based applications, Outlook, Google, Internet Explorer, etc).

Again, do not write passwords down and store them anywhere in your office. Do not store passwords in a file on ANY computer system (including iphone, ipads or similar devices) without encryption.

Change passwords at least once every six months (except system-level passwords which must be changed quarterly). The recommended change interval is every four months.

If an account or password is suspected to have been compromised, report the incident to <PRACTICE NAME> and change all passwords.

Password cracking or guessing may be performed on a periodic or random basis by <PRACTICE NAME> or its delegates. If a password is guessed or cracked during one of these scans, the user will be required to change it.

  1. Application Development Standards

Application developers must ensure their programs contain the following security precautions. Applications:

  • should support authentication of individual users, not groups.
  • should not store passwords in clear text or in any easily reversible form.
  • should provide for some sort of role management, such that one user can take over the functions of another without having to know the other’s password
  1. Use of Passwords and Passphrases for Remote Access Users

Access to the <PRACTICE NAME> Networks via remote access is to be controlled using either a one-time password authentication or a public/private key system with a strong passphrase.

  1. Passphrases

Passphrases are generally used for public/private key authentication. A public/private key system defines a mathematical relationship between the public key that is known by all, and the private key, that is known only to the user. Without the passphrase to “unlock” the private key, the user cannot gain access.

Passphrases are not the same as passwords. A passphrase is a longer version of a password and is, therefore, more secure. A passphrase is typically composed of multiple words. Because of this, a passphrase is more secure against “dictionary attacks.”

A good passphrase is relatively long and contains a combination of upper and lowercase letters and numeric and punctuation characters. An example of a good passphrase:


All of the rules above that apply to passwords apply to passphrases.

2.0 Enforcement

Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.

3.0 Definitions

Terms                                                                Definitions

Application Administration Account  Any account that is for the administration of an application (e.g., Oracle database administrator, EMR administrator).