Operational Resiliency: Mitigating Risks from a Cyber Attack on Third-Party Vendors

Thinking Through Every Potential Scenario

Adding Up the High Costs of Business Interruption

  • Widespread inefficiencies: In an uncertain economy, health plans are under pressure to do more, faster—with fewer people. Without clear direction from business leaders, employees will struggle to regain their productivity after a breach, creating a negative bottom-line impact.
  • Penalties and fines: Non-performance with Medicaid regulations can lead to a Corrective Action Plan (CAP), which could include hefty monetary penalties and potentially even the suspension of Medicaid eligibility.
  • Employee satisfaction: Payer organizations today are leaner than ever, often relying on onshore or offshore staff augmentation for claims processing or other essential workflows. But if a cyberattack forces those tasks back in-house, the workload can quickly become overwhelming—with little time to retrain internal teams.
  • Quality ratings: Ongoing disruption can cause a plan’s Medicare star ratings to decline, which could lead to millions of dollars in lost bonus payments, not to mention damage to a plan’s reputation among members and providers.
  • Data dilemmas: Inaccurate data can erode care quality and member trust—and health plans don’t always realize it’s happening. In one case, a vendor cleansed data but never sent changes back to the health plan, leaving operations leaders completely unaware.

Hope for the Best; Prepare for the Worst

  • Communications guidelines that go beyond simply notifying members of a breach. The strongest plans are both internal and external, including key messages for line-of-business employees, providers, and regulatory bodies like the Centers for Medicare and Medicaid Services (CMS). Set clear expectations in these communications so all parties know what to expect in terms of turnaround times, reimbursements, and other crucial details.
  • Clear step-by-step instructions detailing how employees should respond following a breach. Consider all alternatives and build in redundancies where possible. For example, could the organization use data in its member portals temporarily, or is that data incomplete? Are member ID cards stored in a backup system to mitigate disruptions from an attack on a mail room or print vendor?
  • Resiliency without extra complexity. Two potential ways to accomplish this:
    • Consider redundant vendors for resiliency
    • Strengthen contractual service line agreements (SLAs) in existing contracts to ensure faster response and recovery times

Partner Up to Keep Business Moving

Even the Playing Field with IT and Operations 

Vice President