Key Takeaways
- In healthcare payment workflows, sensitive information often moves across interconnected systems, which expands the risk of data exposure.
- Front-desk, phone, portal, and recurring payments can all expand PCI scope if raw cardholder data enters or is connected to internal systems.
- Encryption at the point of interaction and secure phone-payment capture can help keep raw payment data out of healthcare environments.
- Tokenization helps reduce the long-term risk of exposure by replacing sensitive data with tokens that can still support repeat payments.
- A consistent payment security architecture across a healthcare network can improve governance and limit breach impact while reducing PCI scope.
Healthcare systems today hold enormous amounts of data: years of health history including protected health information (PHI), personally identifiable information (PII) such as Social Security numbers and birth dates, and payment data from transactions.
That’s a lot of sensitive information in one environment, moving across multiple systems. To keep data protected, any security gaps need to be identified before attackers find them first.
Why Are Healthcare Payment Workflows a Growing Security Risk?
Healthcare payment workflows are a high-value target for attackers because they sit at the intersection of PHI, PII, and payment data. Information can move through a wide range of environments, including into legacy systems that weren’t designed with today’s security requirements in mind. Transactions can happen in person, over the phone, online, and other channels that all need to be secured.
Protecting healthcare payment environments requires complying with both the Health Insurance Portability and Accountability Act (HIPAA), which governs the security and privacy of health information, and the Payment Card Industry Data Security Standard (PCI DSS), which establishes security requirements for organizations that store, process, or transmit payment card data. When payment workflows are poorly designed, they can expand PCI scope along with compliance costs and security risk.
Risk #1: Front Desk Payment Collection Expands PCI Scope
Front desk payments can create unnecessary risk if raw card data is allowed to enter hospital systems.
Where the Risk Comes From
The risk often starts with point-of-sale (POS) devices connected to hospital networks or shared infrastructure. If card data passes through internal systems before encryption, systems that were never meant to handle payment data may become exposed.
Why This Creates PCI Audit Gaps
PCI scope covers not only systems, people, and processes that store, process, or transmit raw cardholder data, but also systems that connect to or can affect the security of the cardholder data environment. If a hospital uses a PCI-validated payment terminal but doesn’t pay attention to the connected systems and data flows, audit gaps can appear.
How to Reduce Risk
Encrypt cardholder data, converting it into unreadable text that can only be turned back into its original form with the correct decryption key. Point-to-point encryption (P2PE) makes this conversion at the point of payment to prevent raw data from getting into internal systems. Choosing a P2PE solution that’s PCI-validated can help significantly reduce PCI scope.
Risk #2: Call Centers and AI Payment Capture Expose Card Data
Payments made by phone can expose card data if they involve human agents, recording systems, or automation tools.
Where the Risk Comes From
Card data can be heard by call center employees, keyed into systems, or captured in recordings. AI transcription, voice-analysis, and other automation tools may also become part of the payment environment if they touch or can affect the security of card data.
Why This Creates PCI Audit Gaps
Audit gaps can appear when call recordings, agent desktops, transcripts, or AI tools are not treated as part of the payment environment.
How to Reduce Risk
Remove card data from agent environments. Let customers enter card details through dual-tone multi-frequency (DTMF) masking, which hides keypad tones and routes the payment data through a controlled payment service, or secure interactive voice response (IVR), which routes the data through a protected automated system.
Risk #3: Patient Portals Expand the Digital Attack Surface
Portals that patients use to make payments can enlarge PCI scope if not properly contained.
Where the Risk Comes From
As card data is entered or stored, risks can arise, especially if the portal connects directly into billing systems or the electronic healthcare record (EHR) to mix payment into clinical or administrative systems.
Why This Creates PCI Audit Gaps
With patient portals, card data sometimes passes through more systems and applications than organizations realize. If raw card data enters the portal or gets exposed through scripts on payment pages, those systems can fall under scope.
How to Reduce Risk
Capture payment data directly within a secure payment environment. Encrypt it while it’s transmitted, and tokenize it – replacing the sensitive data with secure substitute values called tokens – if it needs to be stored or reused for future payments.
Risk #4: Recurring Payment Storage Increases Long-Term Exposure
Repeat payments require storing sensitive information, which comes with its own security challenges.
Where the Risk Comes From
Recurring payments and saved payment methods require systems to keep information available for future use. If this data is stored or shared in its raw form, especially with legacy systems, the cardholder data environment (CDE) and the risks that come with it increase.
Why This Creates PCI Audit Gaps
If healthcare systems are unaware of all the places where payment data is saved or backed up, those systems may remain in scope but be missing from the PCI assessment.
How to Reduce Risk
Replace stored payment data with tokens that allow internal systems to support recurring payments without using raw card data. Remove sensitive data that’s no longer needed, especially from harder-to-secure legacy systems.
Risk #5: Satellite Clinics and Distributed Systems Create Inconsistent Security
As healthcare systems go through mergers, acquisitions, expansions, and upgrades, payment security can get more difficult to manage.
Where the Risk Comes From
Facilities that are part of the same healthcare systems may allow data to move across shared EHRs and connected networks even while using different payment systems and processes that leave security gaps.
Why This Creates PCI Audit Gaps
If security is not managed centrally, systems that fall under PCI scope can escape notice.
How to Reduce Risk
Standardize payment architecture across locations, keeping payment data separate from clinical infrastructure. Encrypt card data before it enters shared systems.
The Common Thread: PCI Scope Expands When Card Data Enters Your Environment
Payment security risks in healthcare are tied to the presence of and connections to raw cardholder data. The more systems handling or connected to that data, the larger the CDE and the higher the audit burden and breach impact.
How Do I Secure Healthcare Payment Workflows?
Healthcare payment security gets easier to manage when the same strategy is applied across every payment system. The goal is to keep raw card data out of the environment wherever possible.
Encrypt Data at the Point of Interaction
Start by protecting card data as soon as it is entered with P2PE. This helps keep raw payment information from moving through internal systems, reducing PCI scope.
Tokenize Payment Data Across Workflows
Tokenize payment information that requires reuse, then use those tokens across workflows to safely support recurring payments and card-on-file programs.
Decouple Payment Systems from Clinical Infrastructure
Keep payment systems separate from clinical infrastructure. This helps prevent cardholder data from getting mixed in with clinical data and increasing PCI scope.
Secure Every Payment Channel with Bluefin
Bluefin helps healthcare organizations secure payment workflows and limit PCI scope with a unified approach across locations and channels.
Our PCI-validated P2PE protects payment information by encrypting card data at entry, while our vaultless tokenization-as-a-service helps protect stored payment methods, PHI, and PII for recurring workflows.
Secure every payment channel. Contact Bluefin to reduce risk across your healthcare payment environment.
Healthcare Payment Security FAQs
What are the most common PCI audit gaps in healthcare?
PCI audit gaps in healthcare commonly occur when raw payment data enters clinical, administrative, or third-party systems that are not included in the PCI assessment. If those systems store, process, transmit, or can affect payment data, leaving them out creates a compliance gap.
Why do payment workflows expand PCI scope?
Payment workflows expand PCI scope when they allow cardholder data to pass through more systems. Any system that handles or can affect the security of that data may need to be included in the PCI assessment.
How can hospitals reduce PCI scope without replacing systems?
Hospitals can reduce PCI scope by keeping card data out of existing systems through PCI-validated P2PE, tokenization, hosted payment fields for online payments, and secure IVR or DTMF masking for phone payments.
Are patient portals a security risk for payments?
Portals can create a payment security risk if they collect card data directly or send payment information to connected systems. Even embedded payment pages can introduce risk if third-party scripts on the page interfere with how card data is captured and moved.
How does encryption reduce payment security risk?
Encryption protects payment data by converting it into unreadable ciphertext. Without the correct decryption key, intercepted or exposed data is generally unusable to an attacker.
