Healthcare organizations invest heavily in electronic health record systems, cybersecurity software and employee training. However, printers, copiers, scanners and fax systems can still create serious gaps in their security strategy. For example, patient intake forms, prescriptions, billing records, lab results, referral documents and insurance information regularly pass through office print devices. An unattended document, unsecured scan-to-email workflow or improperly erased copier hard drive may expose protected health information.
As a result, HIPAA-compliant printing involves more than purchasing a printer with security features. Healthcare organizations must also control how employees print, access, store, scan, fax and dispose of patient information.
The HIPAA Privacy Rule protects medical records and other individually identifiable health information. Meanwhile, the HIPAA Security Rule requires covered entities and business associates to use appropriate administrative, physical and technical safeguards to protect electronic protected health information, or ePHI. Modern printers and multifunction copiers connect to business networks, store data and transmit documents, healthcare organizations should manage them as network endpoints—not just office equipment.
What Is HIPAA-Compliant Printing?
HIPAA-compliant printing is the use of policies, technology and employee procedures to protect patient information throughout the entire print and document lifecycle.
That lifecycle may include:
- Sending a document to a printer
- Holding the print job in a queue
- Authenticating the employee
- Releasing and collecting the document
- Scanning or faxing information
- Storing data on a printer hard drive
- Servicing or replacing the device
- Destroying printed documents
In practical terms, no single printer purchase can guarantee HIPAA compliance. The HIPAA Security Rule is flexible and technology neutral. Organizations must evaluate their own risks and select reasonable safeguards based on their size, capabilities, infrastructure and exposure to ePHI. A printer may offer features that support HIPAA compliance, but the organization remains responsible for configuring the equipment correctly and creating secure procedures around it.
Why Printers and Copiers Can Create HIPAA Risks
Today’s multifunction printers perform many of the same functions as computers. They may store, process or transmit data when employees:
- Print patient records
- Scan documents to email
- Copy insurance cards
- Fax prescriptions or referrals
- Save documents to network folders
- Connect to cloud storage
- Access electronic health record systems
- Print remotely
Common healthcare printer security risks include:
- Patient documents left in output trays
- Shared usernames and passwords
- Default administrator credentials
- Outdated device firmware
- Unencrypted print traffic
- Unsecured scan-to-email functions
- Incorrect fax numbers
- Unrestricted access to device settings
- Stored files remaining on printer hard drives
- Copiers returned after a lease without verified data removal
The Federal Trade Commission warns that digital copier hard drives may store information from documents that were copied, printed, scanned, faxed or emailed. That stored information can be exposed through remote access or extracted from a removed hard drive when organizations do not protect it. Make printer and copier security an important part of a healthcare organization’s broader HIPAA risk-management strategy.
HIPAA Printing Security Checklist
A healthcare print environment should address the following controls:
| Security control | Risk it helps address | Information to document |
|---|---|---|
| Secure print release | Documents left in output trays | Print-release settings and procedures |
| Individual authentication | Unauthorized device access | User access and login records |
| Data encryption | Intercepted or exposed data | Encryption configurations |
| Automatic data overwrite | Recoverable hard-drive information | Overwrite and deletion settings |
| Firmware management | Known device vulnerabilities | Update and maintenance records |
| Audit logging | Untraceable print activity | Print, scan, fax and login logs |
| Physical access controls | Public access to devices | Printer locations and access procedures |
| Secure disposal | PHI placed in standard trash | Destruction policies and vendor records |
| Device retirement procedures | Data left on returned equipment | Data-erasure verification |
| Employee training | Mistakes and improper handling | Training dates and attendance records |
1. Use Secure Print Release
Secure print release, also known as pull printing, holds a document in a protected queue instead of printing it immediately. The authorized employee must authenticate at the device before the document is released. Authentication methods may include:
- Employee ID cards
- Personal identification numbers
- Usernames and passwords
- Mobile authentication
- Single sign-on credentials
Secure print release helps prevent patient information from sitting unattended in an output tray. It can also reduce unnecessary printing because abandoned jobs may expire automatically instead of being printed. When properly configured, the system may also create a record showing who released the document, when it was printed and which device processed it.
2. Require Individual User Authentication
Shared printer accounts make it difficult to determine who accessed a device or completed a specific action. Require individual credentials for employees who print, scan, copy or fax sensitive information.
In addition, use role-based permissions to limit features according to job responsibilities. For example, a medical billing employee may need access to secure scanning and faxing functions, while another employee may only need basic printing access. Consider restricting:
- Scan-to-email
- Scan-to-cloud services
- External faxing
- Address-book changes
- USB storage
- Device configuration
- Administrative settings
Individual authentication improves accountability and helps prevent employees from accessing functions they do not need.
3. Encrypt Data in Transit and at Rest
Healthcare organizations should protect information both while it travels through the network and while it remains stored on a device. Encryption considerations may include:
- Print jobs traveling from computers to printers
- Files stored temporarily in a print queue
- Data stored on printer or copier hard drives
- Documents sent through scan-to-email
- Information transferred to network folders
- Files sent to cloud-printing platforms
- Fax documents processed by multifunction devices
Review the device’s available security settings and confirm that encryption is enabled where appropriate. In addition, replace outdated protocols with more secure alternatives and disable communication methods your organization does not use. Cloud providers that create, receive, maintain or transmit ePHI on behalf of a covered entity or business associate may also have HIPAA business-associate responsibilities. Restrict Physical Access to Print Devices. Technology controls cannot prevent every exposure. Healthcare organizations must also consider where printers, copiers and fax machines are located.
Avoid placing devices that regularly process patient information in:
- Waiting rooms
- Public hallways
- Reception areas accessible to visitors
- Shared building spaces
- Unmonitored storage rooms
- Areas visible from public counters
Whenever possible, place these devices in staff-only areas. High-risk departments may need additional access controls, such as badge-restricted doors or dedicated devices. Organizations should also consider whether unauthorized individuals could view documents, remove printouts, photograph information or access the device’s control panel. Physical safeguards work together with technical controls to reduce unnecessary access to patient information.
5. Secure Printer and Copier Hard Drives
Many multifunction printers and copiers contain storage drives that temporarily or permanently retain document information. Create written procedures for managing stored device data throughout the equipment lifecycle.
Recommended practices include:
- Automatically deleting completed jobs
- Enabling data-overwrite features
- Encrypting device storage
- Limiting saved-document functions
- Scheduling secure data deletion
- Removing stored address books when appropriate
- Erasing data before equipment service
- Verifying data destruction before returning leased devices
- Documenting how retired equipment is handled
The risks are not theoretical. HHS reached a settlement of more than $1.2 million with Affinity Health Plan after an investigation found that the organization returned photocopiers without erasing data from their hard drives. The drives contained ePHI associated with as many as 344,579 individuals. When a printer or copier leaves your organization, obtain written confirmation that stored information has been securely removed or destroyed.
6. Keep Firmware and Security Settings Updated
Printers are network-connected devices, which means outdated software and weak configurations can create cybersecurity vulnerabilities. Include printers and copiers in your organization’s patching and vulnerability-management process.
Your IT team or managed IT service provider should:
- Inventory every network-connected print device
- Change default administrator passwords
- Install approved firmware and security updates
- Review manufacturer security advisories
- Disable unused ports and protocols
- Restrict printer administration to authorized employees
- Remove inactive user accounts
- Review device configurations after major updates
- Replace equipment that no longer receives security support
HHS guidance states that risk analysis should include risks and vulnerabilities associated with unpatched software. This principle should extend to multifunction printers and other devices that create, receive, maintain or transmit ePHI.
Create audit trails and review activity. Logging helps healthcare organizations detect unusual activity, investigate incidents and demonstrate that security controls are being monitored. Depending on the capabilities of your equipment and print-management system, consider tracking:
- User login attempts
- Failed authentication attempts
- Print-job releases
- Scan activity
- Fax activity
- Administrative changes
- Address-book updates
- Use of external storage devices
- Device errors
- Data-deletion events
Collecting logs is only the first step. Assign responsibility for reviewing them and define what types of activity require investigation. For example, repeated failed logins, large print volumes outside business hours or unexpected changes to scan destinations may warrant attention. The level of logging and review should reflect your organization’s risk analysis, infrastructure and operational needs.
7. Train Employees on Secure Printing
Even well-configured technology cannot prevent every human mistake. Employees should understand how everyday print habits may expose patient information. Incorporate print security into HIPAA training, onboarding and periodic security reminders.
Training should cover:
- Picking up printed documents immediately
- Using secure print release
- Confirming the correct printer before sending a job
- Verifying fax numbers
- Confirming scan-to-email recipients
- Avoiding shared credentials
- Reporting lost or misdirected documents
- Protecting documents while working remotely
- Placing PHI in approved disposal containers
- Reporting suspected device tampering
Use realistic examples that reflect employees’ daily responsibilities. A short scenario involving an abandoned lab report or misdirected fax may be more memorable than a general policy statement. Employees should also know exactly whom to contact when a print, scan or fax mistake occurs.
8. Dispose of Printed PHI Securely
Printed patient information should not be placed in an ordinary trash or recycling bin where unauthorized individuals could retrieve it. Healthcare organizations should create clear procedures for disposing of paper records and other materials containing PHI.
Depending on the organization’s circumstances, safeguards may include:
- Locked shredding containers
- Cross-cut shredding
- Pulping
- Burning
- Pulverizing
- Approved document-destruction services
- Certificates of destruction
- Written retention and disposal schedules
HHS does not require one specific disposal method in every situation. Instead, covered entities must review their circumstances and use reasonable safeguards to prevent improper access to PHI during disposal. s should also know how to handle printer test pages, fax confirmations, misprints, labels, cover sheets and handwritten notes that contain patient information.
9. Include Printers in HIPAA Risk Assessments
Healthcare organizations often focus their security assessments on computers, servers, electronic health record systems and email. However, risk analysis should include all systems that create, receive, maintain or transmit ePHI.
HHS describes risk analysis as a foundational step in HIPAA Security Rule compliance. Organizations must accurately and thoroughly assess potential risks and vulnerabilities to the confidentiality, integrity and availability of their ePHI. An environment risk review should examine:
- Device inventory and age
- Printer firmware
- Network exposure
- Default passwords
- User access
- Secure print release
- Encryption
- Scan-to-email workflows
- Fax procedures
- Remote printing
- Cloud integrations
- Hard-drive storage
- Device maintenance
- Vendor access
- Audit logging
- Disposal procedures
- Lease-return requirements
Document any identified risks, assign responsibility for corrective action and establish a timeline for addressing them.
10. Thoroughly Vet Your Print and Copier Vendors
Finally, do print and copier vendor need Business Associate Agreements (BAA)? Not every company that sells, delivers or repairs a printer automatically becomes a HIPAA business associate. A vendor may be a business associate when it performs functions or services for a covered entity that involve access to PHI. HHS generally defines a business associate as a person or entity that performs certain activities or services involving the use or disclosure of PHI on behalf of a covered entity or whether a vendor may:
- Access stored patient data
- View documents during service
- Maintain cloud print queues
- Remotely monitor devices containing ePHI
- Manage scanning or document workflows
- Dispose of devices or hard drives
- Process or transmit PHI
When the relationship qualifies, the parties generally need a Business Associate Agreement that defines permitted uses of PHI, required safeguards, incident-reporting obligations and data-handling responsibilities. Consult your HIPAA compliance or legal advisor when determining whether a specific vendor relationship requires a BAA.
Questions to Ask a Healthcare Print Provider
Before choosing a printer, copier or managed print provider, ask:
- How does the device protect stored data?
- Does it support secure print release?
- Can employees authenticate with badges or individual credentials?
- Can access be limited according to employee roles?
- Does the device support encryption?
- How are firmware and security updates managed?
- Can unused ports and protocols be disabled?
- What activity can the device log?
- Can scan and fax functions be restricted?
- How is stored data removed before a device is returned?
- Will the provider document data destruction?
- Under what circumstances will technicians access stored information?
- Is the provider prepared to sign a BAA when the relationship requires one?
- How quickly can the provider respond to device or security problems?
Choose a provider that can explain both the available technology and the procedures required to use it securely.
Frequently Asked Questions About HIPAA-Compliant Printing
Are printers required to be HIPAA compliant?
In general, HIPAA does not establish a list of approved or certified printer models. Instead, covered entities and business associates must use reasonable administrative, physical and technical safeguards based on their risks.
Printers that support authentication, encryption, secure release, audit logging and data-overwrite capabilities can help an organization build a more secure print environment. However, the equipment must be configured and managed correctly.
Does HIPAA apply to printed patient information?
Yes. The HIPAA Privacy Rule protects PHI in paper, electronic and other forms. By comparison, the Security Rule focuses specifically on ePHI.
For example, a printed patient record requires reasonable privacy safeguards. Meanwhile, the electronic data stored on a multifunction printer’s hard drive may also require Security Rule protections.
Can a printer store patient information?
In many cases, yes. Digital printers and multifunction copiers can store data from documents they print, copy, scan, fax or email. For that reason, organizations should review their equipment’s storage capabilities and enable encryption, automatic deletion or secure overwrite features when appropriate.
Secure print release holds a job until the authorized employee authenticates at the printer. It helps prevent sensitive documents from sitting unattended in output trays.
Should printers be included in a HIPAA risk analysis?
Printers should be included when they create, receive, maintain or transmit ePHI. The assessment should review network connections, user access, stored data, scanning, faxing, remote printing, device disposal and vendor access.
Is scan-to-email HIPAA compliant?
Scan-to-email can support a HIPAA-compliant workflow when the organization applies appropriate safeguards. Those safeguards may include encryption, access controls, approved recipients, secure email systems, employee training and audit records.
However, simply having a scan-to-email function does not make the workflow compliant.
Strengthen Your Healthcare Print Security
Ultimately, HIPAA-compliant printing requires a combination of secure technology, documented procedures and informed employees. Printers, copiers, scanners and fax systems may play an essential role in healthcare operations. However, they can expose patient information when organizations overlook device security, physical access and data disposal.
By combining secure print release, individual authentication, encryption, firmware management, audit logging and employee training, healthcare organizations can reduce avoidable risks. In addition, regular print-environment assessments can identify security gaps before they lead to a privacy incident. Therefore, organizations should review their print environment as part of their broader HIPAA risk-management strategy.
DDL Business Systems helps healthcare organizations evaluate their printers, copiers, scanners and document workflows. Our team can identify potential security gaps, recommend appropriate equipment and help you build a more controlled print environment.
Schedule a free healthcare print-security assessment to learn where your current print environment may be creating unnecessary risk.
Recent Comments