Minimum Acceptable Risk Standards for Exchanges (MARS-E) is a set of guidelines developed to help secure sensitive data within health exchanges. Established and overseen by the Centers for Medicare & Medicaid Services (CMS), these standards protect personally identifiable information (PII) and other sensitive data used in state and federal health insurance marketplaces. Compliance with MARS-E is not only a regulatory requirement but also a vital component in maintaining the security and privacy of health information.
Organizations involved in health exchanges, including state and federal agencies, insurance companies, and third-party administrators, must adhere to MARS-E standards. Compliance helps protect data during processing, for example, during applications, eligibility determinations, and enrollments. A specific example is a state-run health exchange that processes thousands of applications daily and must ensure that the sensitive information is secure, preventing potential breaches that could lead to identity theft or unauthorized access to medical records.
The Scope and Integration of MARS-E Compliance
MARS-E compliance applies to a broad range of organizations, including federal and state marketplaces, state Medicaid agencies, and contractors involved in administering these exchanges. The framework aligns closely with NIST 800-53 standards, which encompass comprehensive control families covering aspects like access control, audit logging, incident response, and more. This alignment with NIST standards ensures that MARS-E provides a robust and detailed approach to security, addressing as much as over 1,000 individual controls across as many as 20 control families. You can find detailed compliance information from CMS here. (https://www.cms.gov/files/document/mars-e-v2-2-vol-1final-signed08032021-1.pdf)
Core Requirements and Best Practices
Achieving MARS-E compliance involves adhering to several core requirements, including:
- Data Encryption: Ensuring all sensitive data is encrypted at rest and in transit.
- Access Controls: Implementing strict controls to manage who can access sensitive information.
- Audit Logging: Maintaining comprehensive logs to track access and modifications to data.
- Incident Response: Developing and regularly updating incident response plans to address any security breaches quickly.
Best practices for meeting these requirements include conducting regular risk assessments, investing in employee training on security protocols, and implementing continuous monitoring systems. These measures help organizations manage the nuances of compliance and maintain a secure operational environment.
Addressing Common Compliance Challenges
Organizations often face challenges in achieving MARS-E compliance, such as limited resources, complex requirements, and a constantly changing threat landscape. Addressing these challenges requires a proactive approach, including prioritizing risk management and leveraging compliance tools that can automate and streamline processes. Furthermore, organizations can benefit from continuous education and staying informed about the latest updates and best practices in the field.
The Risks of Noncompliance
Noncompliance with MARS-E standards can result in severe consequences, including substantial fines and damage to an organization’s reputation. For entities involved in health exchanges, failing to adhere to these standards not only risks financial penalties but also compromises the security and privacy of sensitive data.
The Importance of Third-Party Compliance Audits
Engaging third-party experts for compliance auditing is a valuable step in the compliance process. These professionals offer specialized knowledge and objectively assess an organization’s security measures. By identifying potential vulnerabilities and areas for improvement, third-party auditors can help organizations ensure they meet all necessary controls and maintain a robust security posture. The benefits of third-party audits include a thorough evaluation of security practices, insights into industry best practices, and an unbiased understanding of compliance status.
In summary, staying compliant with MARS-E standards is essential for protecting sensitive data within health exchanges. Organizations can effectively manage compliance challenges and uphold the highest data security standards by keeping up with the latest requirements, implementing best practices, and engaging third-party experts.