HIPAA configurations in Adobe Acrobat Sign Solutions

Enable eligibility for HIPAA compliance

This article is meant for customers who have a BAA in place with Adobe Acrobat Sign Solutions.
Customers that don't have a BAA may not enable the “Linked Business Associated Agreement” setting.

Global Settings admin menu highlighting the disabled "Healthcare Customer" settings

Before processing protected health information (PHI) through Acrobat Sign, your organization must enter into a Business Associate Agreement (BAA) with Adobe.    

Note:

The HIPAA readiness capability is only available through an Acrobat Sign for enterprise or business subscription plan.

Not all accounts will qualify for enablement.

Once the BAA is signed, Adobe will update the back-end settings that will show the Linked Business Associated Agreement as checked.
Note that this setting is view only and never editable by the customer administrator.

Global Settings admin menu highlighting the enabled "Healthcare Customer" settings

When the BAA is signed, and the backend setting is enabled, you can use the following general security recommendations from Adobe to harden your Acrobat Sign account for use with PHI data.

Note:

These are Adobe recommendations only. Customers are responsible for implementing appropriate privacy and security safeguards within their Acrobat Sign account.

It is strongly recommended that the account use SAML/Federated authentication.

  • Accounts that manage user entitlement via the Adobe Admin Console can find those instructions here.
  • Accounts using Acrobat Sign's native identity system can access their SAML settings by logging in as an account-level admin and navigating to Account Settings > SAML Settings.
    • The SAML Mode should be set to Mandatory.
SAML Settings in the Admin menu highlighting the SAML Mode configuration

Accounts that manage their users within the Acrobat Sign web application (not going through the Adobe Admin Console or SAML) should configure strong authentication controls.

Log in as an account-level admin and:

  1. Navigate to Account Settings > Security Settings.
  2. Configure:
    • Single Sign-on Settings:
      • Disable Adobe ID.
      • Disable OpenID.
    • Remember-me Settings:
      • Disable the Remember-me Settings.
    • Login Password Policy (Note: Accounts that manage entitlements via the Adobe Admin Console will not have access to these controls):
      • Enable password duration policy and require the password be changed every 3 months (or fewer).
      • Enable password history policy and prevent reuse of the last 10 (or more) passwords.
      • Allow users 5 (or fewer) attempts to log  in before locking their accounts.
    • Login Password Strength:
      • Set to Strong.
      • Accounts that use the Adobe Admin Console should configure the account to be More Secure.
    • Web Session Duration:
      • Set to 10 minutes of inactivity.
    • Document Link Expiration
      • Set link expiration to 2 days or less.
  3. Save your changes.
Security Settings admin menu highlighting the several security configurations suggested.

Email is generally considered a less secure medium when sending electronic personal health information, as there are several ways that notifications can be a source of ePHI leakage. 

Keep in mind that the name of the agreement is listed in the notification, so patient information (eg, names) should never be used in the title of the agreement. 

Additionally, the agreement itself contains ePHI, so attaching the agreement to the notifications can expose ePHI if the email is intercepted.

  1. Navigate to Account Settings > Global Settings > Attach a PDF copy of the signed document in emails.
    • Set the value to No One.
    • Uncheck Include a link in emails to view the signed agreement.
    • Uncheck Include an image of the first page of the agreement in emails.
  2. Save the changes.
Global Settings in the admin menu highlighting the controls to attach a PDF and display image and link on emails.

Caution:

Do not use personal information in the file names of Acrobat Sign agreements.

Agreement names are exposed within emails.

Completed agreements need to be secured, whether viewed as PDFs or online.

Secure online access with Content Protection

  1. Navigate to Send Settings > Content Protection.
    • Enable the requirement for both Internal and External users to authenticate before viewing the agreement.
    • Enable Use Email OTP when alternative methods cannot be made available.
    • Ensure the Maximum failed attempts value is 5 or less.
  2. Save the change.
The Send Settings admin menu highlighting the Content Protection controls

Secure the PDF with a password

  1. Navigate to Send Settings > Signed Document Password Protection.
    • Set the value to Enforce senders to password protect signed documents.
  2. Save  the change.
The Send Settings admin menu highlighting the "Signed Document Password Protection" controls.

  1. Navigate to Security Settings > Document Password Strength.
    • Set the value to Strong.
  2. Save the change.
Security Settings admin menu highlighting the Document Password Strength controls

Note:

We strongly recommend that account administrators review the other security settings in Account Settings > Security Settings.

Sign a Business Associate Agreement (BAA)

Before processing protected health information through Acrobat Sign, your organization must enter into a Business Associate Agreement (BAA) with Adobe.    

Contact your sales or channel representative to determine eligibility and establish a BAA with Adobe.

When contacting your sales or channel representative regarding BAA eligibility, you must include the Account ID for your Acrobat Sign account. The Account ID can be found in the Global Settings section of the account-level admin menu:

Global Settings page in the admin menu highlighting the account ID

 

After the BAA is accepted and executed, the check box for linking the BAA will be checked, and your account will be enabled.  

Global Settings admin menu highlighting the enabled "Healthcare Customer" settings

 Adobe

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