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standards associated with the chapter. Ms. Cole has served as a liaison
between HSIS and the Health Information Management Department for the
past few years, specifically assisting with the shift from paper to electronic
documentation. Ms. Cole has a Master of Science degree in Health
Informatics, as well as an undergraduate degree in Mathematics from Bethel
College.
Joseph Dalton specializes in cyber security, business intelligence, database
architecture and development. He is currently the Technology Director at
Clinical-Security, and Course Director at Full Sail University where he
teaches databases and information security. He holds a Masters Degree in
Modeling and Simulation from the University of Central Florida, with an
emphasis in mathematical modeling.
Darren D. Dannen, CISSP, has extensive work experience in enterprises as
an information architect, technical engineer, project manager, security
specialist, and consultant. Additionally, he has extensive training through the
United States Navy in Information Assurance and has an MS in Network
Security from Capitol College and an MBA from University of Mary. He is
aggressive in pursuing the strategic use of technology to improve the role of
information security.
Mark W. Dill is the Director of Information Security at Cleveland Clinic.
Mr. Dill is responsible for the deployment of information security and
disaster recovery best practices and compliance with HIPAA, PCI, and
Internal Control Effectiveness/SOX regulations and standards. With more
than 25 years of IT and technical management experience, Mr. Dill’s focus is
on implementing strategic and tactical security initiatives.
Brian Evans, CISSP, CISM, CISA, CGEIT, has partnered with Tom
Walsh, CISSP, to assist healthcare organizations throughout the country with
building regulatory compliant information security programs. With more than
20 years of combined experience in health IT management, consulting and
information security, Mr. Evans previously served as the Information
Security Officer at The Ohio State University Health System. He also led the
Computer Incident Response and Forensic Investigations teams for
Nationwide Insurance, and was Vice President, IT Risk Management, at
KeyBank and JPMorgan Chase. Mr. Evans held IT management positions at
the Ohio Department of Health and started his career as a medic in the US
Air Force. He has earned a Master’s in Public Administration from the
University of Cincinnati and a BS in Business Management from the
University of Maryland.
Susan Gatehouse is a tenured expert in health information management with
more than 25 years’ experience in revenue cycle–related matters to include
the management and protection of healthcare data. Ms. Gatehouse is a
nationally recognized speaker regarding health information management and
the revenue cycle. Ms. Gatehouse has also served as editorial advisor and
technical editor for The Coding Institute publications, authored a coding
manual for medical device manufacturer Medtronic Sofamor Danek, and
acted as a lead consultant in a national Medicare fraud and abuse
investigation. Ms. Gatehouse was a contributing consultant in the
development of “A Purchasers Guide to Clinical Preventive Services,
Moving Science to Coverage” for the Centers for Disease Control and
Prevention (CDC), Preventative Health Services Division. Ms. Gatehouse has
developed and implemented numerous coder training programs for inpatient,
outpatient, and physician services, as well as delivered educational seminars
and produced operational assessments for a range of nationwide healthcare
facilities. She has facilitated ICD-10 introduction, training, assessments, and
APC readiness programs for hospitals ranging from 100 to 900 beds. Most
recently, Ms. Gatehouse implemented clinical documentation improvement
programs for community and teaching acute-care medical centers.
Additionally, she has implemented a hospital and physician coding
compliance program for one of the top 10 largest health systems in the
nation. As remote coding has become commonplace in the HIM industry, Ms.
Gatehouse has assisted facilities in implementing remote coding programs as
well as establishing the framework for supporting and sustaining virtual
coding management. A member of the Certified Coding Specialist (CCS)
Construction Committee and the Coding Roundtable Committee for Georgia,
Ms. Gatehouse is Past President and Legislative Chairperson of the Greater
Atlanta Health Information Management Association. She is an active
member of the American Health Information Management Association, and
American Academy of Procedural Coders. She is the recipient of the 2007
Professional Achievement Award, presented by Georgia Health Information
Management Association. Ms. Gatehouse is a Certified ICD-10 Coding
Trainer.
Buddy Gilbert, CCNA, is the Network Architect for UAB Health System.
He is involved in all aspects of design and implementation of the data
network and services, connecting close to 30,000 Ethernet ports. His team is
also responsible for network security firewalls, VPN connectivity, server load
balancing, DNS/DHCP, URL filtering, more than 3.5 million square feet of
wireless network, and managing a team of 10 people. Mr. Gilbert has worked
for UAB Hospital for more than 24 years and has witnessed first-hand the
exponential growth and change the industry experienced in the last quarter
century.
Dennis Henderson is a Security Professional with 26 years’ industry
experience. He is a 12-year Air Force military veteran and possessed a top
secret clearance. He was also the Director of Security for Major Midwest
Bank for nine years. Mr. Henderson is a Certified Information Security
Manager with and is the lead consultant for a Midwestern security consulting
practice specializing HIPAA security compliance.
Ander Hoaglund is a digital forensic analyst and incident responder. He
received his Masters in Digital Forensics from the University of Central
Florida in Orlando, where he works for a corporate security team. When he is
not chasing hackers he is advising clients on how to best implement security
solutions to prevent future breaches.
Judi Hofman, CAP, CHP, CHSS, is a Privacy and Information Security
Officer for a four-hospital health system in central Oregon. Ms. Hofman has
been co-chair for American Health Information Management Association’s
(AHIMA) national Privacy and Security Practice Council, is a contributing
author, and presents nationally on HIPAA privacy and security. She is the
current Director of Education for Oregon’s Health Information Management
Association state chapter of AHIMA. Ms. Hofman has her Bachelor of
Science, certificate in Health Services Administration, and is working on her
Master’s degree in Biomedical Informatics. Ms. Hofman is a Certified
HIPAA Professional (CHP), Certified HIPAA Security Specialist (CHSS),
Certified Administrative Professional (CAP), and Certified in Healthcare
Privacy and Security (CHPS).
Michele T. Kruse, MBA, RHIA, CHPS, has more than 30 years of
experience in health information management and information systems
specializing in EHR system implementation and support in a multiple
hospital/large physician clinic setting, policy and procedure development,
privacy/security concepts and standards, and regulatory compliance. She is an
active member of AHIMA serving as a member of the Privacy and Security
Practice Council.
Susan Lucci, RHIT, CHPS, CMT, AHDI-F, served as a privacy officer for
nationally based organizations for nearly 10 years before launching her own
HIPAA consulting business. She has written numerous articles for the
Journal of AHIMA, Advance and For the Record. Ms. Lucci is the 2013 Co-
Chair for the Privacy and Security Practice Council for AHIMA. She is a
graduate of St. Petersburg College and the University of Cincinnati.
Margaret Marchak, Esq., is a shareholder in the Troy, Mich., office of Hall,
Render, Killian, Heath & Lyman. Ms. Marchak primarily represents
healthcare providers with technology procurement and agreements; hospital-
physician transactions; HIPAA privacy and security issues; governance in
nonprofit/tax-exempt organizations; and corporate compliance programs. She
has a particular interest in health information technology law, including
electronic medical records, software licensing, technology agreements,
outsourcing, privacy and security issues, and HIPAA compliance. As part of
her practice, Ms. Marchak works on various state of Michigan initiatives to
facilitate health information exchange (HIE) in the state by serving as Co-
Chair for the Legal Workgroup for the State of Michigan’s Health
Information Network (MiHIN). She also chaired another legal workgroup to
identify state law barriers to, and opportunities for, HIE in Michigan for a
HISPC project. Ms. Marchak has developed a RHIO Toolkit of forms for the
Michigan Resource Center, which provides resources for regional health
information organizations in Michigan. She also served on a HISPC Multi-
State Steering Committee on 42 CFR Part 2 to develop approaches to
facilitate HIE with respect to highly protected substance abuse/mental health
records. Ms. Marchak has lectured nationally and locally on healthcare and
information technology issues, including the HITECH Act’s opportunities for
HIE and its impact on HIPAA at the Annual HIMSS Conference &
Exhibition, the HIT Summit, the HIPAA Summit, and other venues. Ms.
Marchak is a Fellow of the Health Law Section of the State Bar of Michigan
and a member of the American Health Lawyers Association, HIMSS, and the
National Association of College and University Attorneys.
Melissa Markey, Esq., is a shareholder with Hall, Render, Killian, Heath &
Lyman, one of the nation’s top health law firms, and is licensed to practice as
an attorney in Texas and Michigan. Her practice focuses on technology and
life sciences issues, especially electronic medical records, data privacy and
security, mobile medical applications, e-Discovery, health information
exchange, innovations in health technology, and software licensing. She leads
the Life Sciences team at Hall Render and has a particular interest in legal
issues at the developing edge of technology. Ms. Markey is a paramedic, is
on the Board of Directors of the American Health Lawyers Association, is a
member of HIMSS and the Michigan chapter of HIMSS, and the computer
law sections of the American Bar Association as well as the State Bars of
Texas and Michigan. She is a nationally recognized author and presenter on
electronic medical records, data privacy and security, clinical research and
human-subject protection, the clinical-technology interface, research
misconduct, and emergency preparedness and response law.
Joseph W. Popinski III, PhD, CISSP, CPP, CISM, CFE, is the acting
Information Security Officer for University of Alabama at Birmingham’s
Office of the Vice President for Information Technology and adjunct assistant
Professor at the University of Alabama in Huntsville (2005-2011) where he
taught graduate courses in a Master’s program in information security. He is
responsible for information security at UAB, including security architecture,
strategic planning, DR, compliance, cyber security investigations, risk
management, security technical monitoring, forensics, and other security
related functions. Dr. Popinski has a wealth of information security
experience spanning a more than 40-year career, including serving in
multiple information security positions at BellSouth Corporation, Internet
Security Systems, KPMG, Dynetics, and NASA. He has a BS and MS in
Electrical Engineering, an MBA, and a PhD in Information Assurance. He
maintains several professional certifications, is a lifetime member of the
IEEE, a senior member of the ISSA, is an (ISC)2 test supervisor, and actively
participates in multiple professional societies.
Kim E. Sassaman, CISSP, has more than 20 years of information
technology security experience across multiple business verticals. His focus
was primarily on the financial services sector having worked for Charles
Schwab, Ameriprise Financial, and American Express. Mr. Sassaman has
focused on healthcare the past four years. Mr. Sassaman is the Chief
Information Security Officer for Presbyterian Healthcare services. Presby-
terian is an integrated delivery system that is comprised of eight hospitals, 40
clinics, a physician group, and a health plan. Presbyterian is a pioneer ACO,
has innovated home health and telemedicine, and is in the midst of deploying
EPIC. Mr. Sassaman has a CISSP, is an ISO 27001 auditor, and graduated
from Capella University with a BS in information security. He is a member
of the HIMSS Privacy and Security Committee and is active in ISACA.
Shelia T. Searson, CIPP, moved to the position of Privacy Officer for the
University of Alabama at Birmingham (UAB) Health System in October
2011. The Privacy Officer oversees all ongoing activities related to the
development, implementation, maintenance, and compliance of the UABHS
policies and procedures covering the privacy of and access to patient health
information in compliance with federal and state laws and the UABHS
information privacy practices. Prior to transitioning to Privacy Officer, Ms.
Searson served as Program Director in UAB’s HIPAA Office where she was
a member of a UAB/UABHS HIPAA Team responsible for communicating
and initiating activities needed to comply with the HIPAA Privacy Rule and
Security Regulations and related to all UAB, as well as the UAB Health
System HIPAA covered entities. Ms. Searson holds a baccalaureate degree in
Speech Communications from Shorter College in Rome, Ga. Her professional
affiliations include the International Association of Privacy Professionals,
through which she is a certified information privacy professional, and the
American Health Information Management Association.
Linda Wilson, MSHI, RHIA, is the Manager of the Record Center for the
University of Alabama at Birmingham (UAB) Health System, an Instructor in
the School of Health Sciences at Colorado Technical University, the
President of the Birmingham Regional Health Information Management
Association, and the Secretary for the Birmingham Chapter of the American
Records Management Association. Mrs. Wilson teaches courses in health
data management, healthcare organization, electronic health record and
ethical/regulatory issues in healthcare. She has also taught in the Health
Information Management program at UAB. Mrs. Wilson continues to
demonstrate dedication to the HIM world by mentoring students and
participating in the Action Community for Excellence program (ACE). She is
a Registered Health Information Administrator through the American Health
Information Management Association (AHIMA) and utilizes this credential
in the offices that she has held on the Board of Directors, House of Delegates
to the National Association, Community Education Coordinator, Advocacy,
and Workgroup Delegate.
Table of Contents

Acknowledgements
A Tribute to Terrell W. Herzig

Chapter 1: The Importance of Information Security in Healthcare

By Terrell W. Herzig, MSHI, CISSP

Chapter 2: Information Security Frameworks

By Joseph W. Popinski III, PhD, CISSP, CPP, CISM, CFE

Chapter 3: Information Security Planning

By Kim E. Sassaman, CISSP

Chapter 4: Risk Analysis

By Susan Lucci, RHIT, CHPS, CMT, AHDI-F, and Tom Walsh, CISSP

Chapter 5: Senior Management Oversight and Involvement

By Mary Anne S. Canant, MBA, CISA, CISSP, CHFP

Chapter 6: Information Security Regulations

By Susan Gatehouse

Chapter 7: Security Policy Development

By Judi Hofman, CAP, CHS, CHSS, and Michele T. Kruse, MBA, RHIA,
CHPS

Chapter 8: The Concept of Security Controls

By Kim E. Sassaman, CISSP

Chapter 9: Access Control

By Brian Evans, CISSP, CISM, CISA, CGEIT

Chapter 10: Network Security

By Buddy Gilbert, CCNA

Chapter 11: Use of Encryption

By Brian Evans, CISSP, CISM, CISA, CGEIT

Chapter 12: Managing Mobile Devices

By Mark W. Dill, Brian Evans, CISSP, CISM, CISA, CGEIT, and Tom Walsh,
CISSP

Chapter 13: Application Security

By Joseph Dalton and Ander Hoaglund

Chapter 14: Information Security Operations

By Darren D. Dannen, CISSP

Chapter 15: Security Considerations in Technology Contracting

By Melissa Markey, Esq., and Margaret Marchak, Esq.

Chapter 16: Business Continuity and Disaster Recovery

By Tom Walsh, CISSP

Chapter 17: Change Control and Change Management

By Michelle Bigelow

Chapter 18: Testing Your Technical Controls

By Tom Walsh, CISSP, and Dennis Henderson

Chapter 19: Auditing Your Program

By Mary Anne S. Canant, MBA, CISA, CISSP, CHFP

Chapter 20: Incident Handling

By Shelia T. Searson, CIPP, and Jennifer L. Cole, MSHI

Chapter 21: Information Systems Implementation

By Linda Wilson, MSHI, RHIA

Appendix A
Appendix B
Index
Acknowledgments

Sincere gratitude is offered to those who made this book possible:

• To the Herzig family for their courage and loving kindness; our hearts
are with you.
• To Matt Schlossberg of HIMSS for his patience and perseverance in
making this book a reality; for deciding to continue the project in
Terrell’s absence; and for deciding to keep Terrell’s name on the book as
an editor and author.
• To Terrell’s colleagues at the University of Alabama Birmingham and
UAB Health System for their contributions in writing several chapters of
the book.
• To Brian Evans for volunteering to write two chapters and co-author a
third at the last minute.
• To Lisa Gallagher for her leadership and guidance.
• To Valerie, my wife, for her understanding of my long hours and for all
of her help.
• To Jeff Brandt for his work with the mHIMSS Mobile Task Force and
his ideas on mobile device security.
• To Jeremy Higgins for the cover artwork and design.

Thank you all for your help and dedication to this project.

Respectfully,
Tom Walsh, CISSP
A Tribute to Terrell W. Herzig

This book is dedicated to Terrell W. Herzig. His life was cut short while
doing one of the things he loved best, riding his motorcycle home from work.
He was a devoted husband and the loving father of three children and
godfather to a fourth. Terrell was always enthusiastic about computer
technology, and in information security he’d found the field he enjoyed best.
He was excited to be working on this, his second book on the subject. He
would have been proud to see the end result.
—Cindi Herzig

Terrell Herzig was a great person and a wonderful friend. It was a privilege
knowing him. I believe the best way I can attest to this is by sharing a couple
of short stories.
 A few months after my son Matthew was killed, I received a call from
Terrell. He told me he was dedicating the first HIMSS book he was working
on to my son. I remember his call and the way it made me feel. Most authors
dedicate a book to their own family or to someone they admire. Terrell never
met Matthew, yet he decided that this is what he wanted to do. My family
was very appreciative of that gesture and Terrell’s legacy became
incorporated into his name. At the Walsh household he is known as, “Terrell,
the guy that dedicated the book to Matthew.”
My second story deals with Terrell’s friendship. Regardless of the time
that had passed, every time Terrell and I spoke or met, our conversation
would take off as if we had just spoken the day before. I remember on one of
my business trips to Birmingham, Terrell and I used some free time to get
caught up on family and on one of our favorite TV series at that time,
Battlestar Galactica.

About a year later during my next visit to Birmingham, Terrell surprised

me with a gift. He had built and hand-painted a model of the Battlestar
Galactica. It was very impressive. I asked him how long it took and in
Terrell’s typical, nonchalant Southern style said, “Oh, 12 or 15 hours.” I
could not believe it! He gave up that much of his time to do something like
that for me. I asked him, “Why?” And he replied, “Because I knew you
would appreciate it.”
 I did appreciate the model and proudly displayed it on a bookshelf in my
office where it sits today. When family members saw it, they each had the
same reaction and essentially the same discussion took place.
“Wow! Where did you get that?”
“My friend Terrell made it for me.”
“The guy that dedicated the book to Matthew?”
“Yep, the guy that dedicated the book to Matthew.”
Terrell will never be forgotten. “So say we all.”
—Tom Walsh, CISSP

Although we knew each only for a few months, Terrell and I developed a
great friendship and mutual respect for each other’s abilities, skills, and
accomplishments. We met every two weeks for coffee at Dunkin Donuts on
the UAB campus to discuss how we could work together to improve the
information security posture of both the UAB Health System and the UAB
campus environments. Terrell “offered” me the opportunity to contribute to
this book; little did I know at the time that by accepting this opportunity it
would turn into his legacy. Terrell, I owe you a large measure of gratitude
and thanks.
—Joseph W. Popinski III, PhD, CISSP, CPP, CISM, CFE

Terrell Herzig will forever be the optimist and a humble, endearing educator.
He had a love of learning and a willingness to transfer knowledge that cannot
be surpassed. He has placed his mark on an industry while translating
complicated subject matter into simple terms. The mark of a true genius.
—Susan Gatehouse

Terrell was a man of integrity, devoted to his family, committed to his

profession. He maintained a broad spectrum of interests and mastered more
subjects and skills than most dare to explore. Terrell was generous. He shared
his knowledge, friendship, and laughter. Those of us who knew him well
loved him for these reasons and miss him dearly.
—Mary Anne S. Canant, MBA, CISA, CISSP, CHFP

Words cannot begin to describe Terrell Herzig, who was no ordinary man. I
came to know Terrell as one of my professors while attending graduate
school where he taught information security and database classes. He was
always able to explain even the most complex computer or information
security concept in language anyone could understand. He was impressive
with his vast amount of knowledge and understanding; however, I came to
really appreciate Terrell when I began working with him at UAB. Terrell
became a trusted co-worker and, most importantly, a friend. He is missed
greatly, especially his laugh; he will always be remembered.
—Jennifer L. Cole, MSHI

Where do I start, which perspective do I take, or even which decade do I

reference as I write my tribute to Terrell Herzig? Terrell was my first
computer lab designer/ technician, my network class instructor, my project
advisor for a statistics project in graduate school, my partner on a nuclear
power consulting project, my lecturer on information security for whatever
professional organization committee I was serving, my co-instructor for the
privacy and information security class for 10 years, my constant unknown
advisor for information security questions, my Information Security Officer,
and one of the best friends a CIO could ever have. From this long list of
“my’s,” it is obvious how long and how closely Terrell and I worked together
and, therefore, very difficult to express just how much, in so many ways, I
miss him. Terrell was a man of many qualities and varied interests who had a
tremendous influence on my life. Most of all, when Terrell was here, no
matter the information security crisis and how panicked I might become, I
was always confident that Terrell would get us through the crisis, and he
always did. I miss him desperately.
—Joan Hicks, MSHI, RHIA, CIO for UAB Health System

Terrell Herzig was dedicated to his family, friends, and work. He was
brilliant. His knowledge, experience, and wisdom surpassed his 48 years—
whether the topic of discussion was computers, car repair, photography, or
general trivia—just name the topic! He laughed easily and often—taking his
work seriously, but never himself. Terrell was my colleague at UAB for more
than 20 years. But, most importantly, he was my friend. He is sorely missed
and definitely remembered.
—Shelia T. Searson, CIPP

Terrell Herzig was an instructor, mentor, and friend to me. He paved the path
for resolution to security issues and taught health informatics students more
than just a thing or two about privacy and security. He was an encourager to
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"I suppose then you would have every one go on in earthly

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"I would have all men and women lead religious lives, ay,
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Anne, in a more subdued voice.

"I am not so sure of that, dear sister," remarked Sister

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seem to enjoy my prayers now a great deal more than I did
when I had little or nothing else to do than to pray. I do
believe one reason is that my health is so much better now
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what a home is like. I never knew before. When I go back
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you a born lady, but yet—"

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best. I would I could find more to make myself useful."

"Dear lady, don't fret about that," said Cicely. "I am sure
you are a comfort to all of us. Why, the very little ones who
come to the shop are ready to worship you, if you do but
speak to them."

"Why should you not set up a school for little girls, madam,
since you are so fond of children?" asked Jack.

"Hush, my son!" said his father.

"Pray let him speak," said Sister Barbara, eagerly. "What

were you thinking of?"

"There are so many little maids about here," said Jack,

"who are too young to be of much use at home, who yet are
old enough to learn to read and work, ay, and to learn all
kinds of mischief. Why should you not gather them into a
school and teach them all the good you know?"

"That seems to me a good motion," said Sister Barbara. "I

used to be thought good at teaching, you know, Anne."

"Yes, you were far better and more skilful than any one else
in the convent, except—" Anne checked herself and turned
pale.

And Sister Barbara sighed and was silent for a moment.

Jack guessed that they were speaking of Agnes Harland,
and he sighed in his turn.

"I love children and young folks so well, I believe that is the
secret of the matter," said Sister Barbara, recovering her
cheerful tone. "I should love dearly to have a dozen or so of
the little things together every day and teach them to knit
and spin, and perhaps to do white seam and cut-work. It
would be helping them to earn a living as well as to be
useful at home, would it not?"

"It would indeed, madam; and you might teach them their
religious duties at the same time."

"I will talk to the priest about it," said Sister Barbara.

"I am sure our Sir William will be pleased," remarked Cicely.

"He has always wished for a girls' school. But it seems like a
come down in life for you to be teaching a dame-school for
children such as these, not young ladies, but daughters of
tradesfolk and the like."

"I suppose our Lord died for tradesfolk and laborers as well
as for gentlefolks," said Jack smiling.

"That is very true," said Sister Barbara; "and a religious

person ought not to think any office too lowly which is done
for the good of others. I have heard that our holy father the
Pope washes the feet of twelve old men every Holy
Thursday."

"Yes, with a gold basin and a damask cloth," said Jack dryly.
"Master Fleming told me about that. He has seen the
ceremony."

"I should like to meet this same Master Fleming," said the
baker.
"He bade me say to you, father, that he desired to make
your acquaintance," said Jack eagerly. "I had so much to
think about, I had well-nigh forgotten the message. He is
Sir William's cousin as I told you, and is to stay here a
month or more. I am sure you will like him, for he has
travelled a great deal, and you know you love travellers'
tales."

"Ay, that I do. Well, we will go to see him, and have him
and Sir William home to supper. He has been kind to you,
and that is enough to make me love him."

"Then must you love all the world, and yourself most of all,
for all the world is kind to me," said Jack; "but when will
you go?"

"Directly, and you will go with me. I am right curious to see

this friend of yours."

"Jack is graver than ever," said Cicely, when Jack had left
the room.

"He seems a wondrous good lad," observed Sister Barbara.

"I had thought all boys rough and cruel."

"They are so, too many of them," answered Cicely; "but our
Jack was never like other boys, even before he took this last
turn. And yet, though Jack is so grave and thoughtful ever
since he came home, he seems happy too. I see him
sometimes sit thinking by himself, and his face shines as if
there were a light within."

"He is much changed," said Anne. "I cannot make him out.
He is not like the same boy he was last winter."

Anne was right. In such circumstances and times as I have

been describing, character develops fast, and Jack had
grown from a schoolboy into a man.

CHAPTER XII.

AN EXPLANATION.

Sir William Leavett caught with avidity at the proposition of

Madam Barbara, as she came presently to be called, to
teach a girls' school in Bridge Street. A room was found in a
house belonging to Master Lucas and suitably arranged; and
here did Madam Barbara set up her sceptre over her
kingdom of about twenty little maids of all ages from three
to twelve, to whom she taught the arts of sewing, knitting,
spinning, and reading, promising to advance the best
scholars as far as white seam, cut-work, and carpet-work,
and possibly even to writing.

Her school soon became very popular, as well with pupils as

with parents. The mothers rejoiced in the manifest
improvement in the manners and appearance of their little
girls and their advancement in all useful arts, and were
flattered that their children should be taught by a "born
lady." The children themselves learned to love their teacher
and to feel themselves exceedingly comfortable under her
gentle but decided sway. It was certainly true, as Master
Lucas had said, that Madam Barbara had a natural talent for
managing children. She knew how to combine the most
absolute authority with great indulgence and kindness. She
knew that the youthful human heart has many avenues of
approach, and that as much might be done by praises and
rewards as by reproof and punishment. She possessed the
inestimable art of prevention—she knew that it was a great
deal better if possible to keep children from being naughty,
than to punish them afterwards. Her sway was so gentle, as
compared with that of Master Crabtree over the boys, as to
arouse some murmurings among the latter, that the girls
should be so much better off than they were.

"Yes, Peggy may well like to go to school," said Mary Brent's

boy Peter, in reply to his mother, who had been holding up
his sister to him as an example. "It is a very different thing.
Madam Barbara is always kind and gentle. She hardly ever
punishes the girls, and when they do well she gives them
cakes and comfits; and praises them beside. Master
Crabtree hardly ever says a good word to a boy, no matter
how much pains he may take; and if he does the least thing
out of the way, whack comes the strap across his back or
hand. If Peggy went to Master Crabtree, she wouldn't be in
such a hurry to get to school, I can tell you."

"No, that I shouldn't," agreed little Peggy, heartily

sympathizing with her brother. "I wish Peter could go to
Madam Barbara, only she doesn't take boys."

"As though I would go to school with a parcel of little

maids," growled Peter; but in his heart he wished so too.

Jack meantime fell very much into his old ways, helping his
father with his accounts, playing with his old schoolmates,
and going to Sir William Leavett for a Greek lesson twice a
week; for, to his own disappointment as well as to that of
Master Crabtree, his father firmly refused to let him go into
school at present.
"He will lose all he has gained if he once gets back into that
close room, and with Master Crabtree to drive him with
whip and spur," said Master Lucas. "I am willing to have him
learn what he can at home, since Sir William is so kind as to
help him; but to school he shall not go for a year."

And as Master Lucas, with all his kindness and gentleness,

was an absolute monarch in his family, Jack was fain to
submit, especially as he found upon making the trial that he
could not bear the confinement for any length of time. So
he gave up the thought of going to school this year and to
Oxford the next, and contented himself with what he could
do at home. He was especially anxious to get on with
Greek, as Master Fleming promised him a copy of Erasmus'
Greek Testament as soon as he was able to read it
intelligently; and with the help of Sir William Leavett, he
made great progress.

Master Fleming still remained in Bridgewater at the house of

his cousin, now and then making an excursion into the
country, especially to the houses of Lord Harland and the
knight of Holford, with whom he seemed to be on terms of
great intimacy. He had been invited to the tables of most of
the substantial citizens of Bridgewater; but while he was
always ready for a friendly chat upon London matters, trade
in general, or any other topic, he was anything but a boon
companion and frowned most decidedly upon any light or
loose conversation. He visited much among the poor of
Father William's congregation, especially among the sailors'
families down by the waterside, and gave a large present in
money to the fund of the almshouses for the widows of
mariners, which had been endowed by the will of a wealthy
ship-owner some years before.

He was often to be found in Master Lucas' shop, sometimes

under the pretext of storing his pockets with cakes and
sweets for the school-children, sometimes merely to have
an hour's talk with the kind genial old man; and he and
Jack took long walks into the country on pleasant evenings,
talking of everything in heaven and earth; Jack asking
endless questions, and Master Fleming listening and
answering with that patient kindness and sympathy which
often produces in an intelligent young person of either sex,
a sort of adoring reverence for an older companion. In
short, Master Fleming won golden opinions from all sorts of
people, from the prior of the convent, whom he informed as
to the best way of supplying his house with almonds and
figs, wax candles and fine cloth, to Mary Brent and her little
children, to whom he gave cakes and toys and more
substantial comforts.

Mary Brent's condition had considerably improved since we

first met her in Master Lucas's shop at the beginning of this
tale. She had recovered from her injury, and thanks to the
long rest enforced by her sprained ankle, and to the
generous diet provided by Dame Cicely, she found herself in
better health than she had been since the death of her
husband. She was thus enabled to take in the fine washing
and ironing in which she excelled, and which was then a
profitable business, owing to the great quantity of laces
worn by both sexes.

Mary Brent was judged to be the neatest hand at a lace or

cut-work falling band, or a lady's stiffened coif and pinners,
of any one in Bridgewater; and thanks partly to Cicely's
active patronage and recommendation, she found plenty to
do. She was able to put in order her house, which had once
been a good one, and to help pay her way by letting
lodgings now and then to the better sort of sea-faring men.
Peter and Peggy both went to school, and Master Lucas
promised to take Peter for an apprentice so soon as he
should be a little older, while Peggy was learning under
Madam Barbara to do the fine sorts of needlework which
would insure her a superior place whenever she should wish
to go to service.

Moreover Mary had received letters and money from her

son in foreign parts more than once—not a great deal, to be
sure, but enough to be a help to her and (what she valued
still more) to show that her Davy was not the scapegrace
that his former masters would have made him out. In short,
as Master Lucas had once prophesied, the sun was
beginning to shine on her side of the hedge, and she could
well afford to dispense with the charity which had been so
grudgingly dealt out to her at the convent gate.

There was one person with whom Jack did not "get on" at
all, and that was his sister Anne. Jack had always loved his
sister dearly, it must be confessed on slight encouragement,
for Anne's system of religious belief led her to look on all
natural family affection with suspicion, as a thing savoring
of "the world," and a hindrance to that ascetic sanctity to
which she aspired. For a time during Jack's long and severe
illness she had seemed to thaw toward him, and to be
disposed to give him her confidence, especially after the
conversation relating to Agnes Harland; and Jack had
looked forward with affectionate impatience to seeing her
again. But he found her, to his great disappointment, frozen
up ten times stiffer and colder than ever.

At first he was unwilling to accept this state of things, and

accused himself of jealousy and unkindness, but he soon
came to see that it was no fancy of his own. Anne avoided
him as much as possible: she would not sit down in the
room alone with him, and seemed actually afraid of him.

Jack felt very much distressed, for aside from his strong
natural affection toward his sister, his heart was full of the
first love and joy of a genuine religious experience; and he
would fain have been on good terms with all the world. He
made many attempts to put matters on a better footing;
but without success. Anne seemed to shrink into her shell
more and more as Jack tried to draw her out of it.

At last, one day finding her alone in her room, he entered it

and closed the door behind him.

"Now, Anne dear, let us have it out," said he. "Do not let us
go on in this uncomfortable way any longer. Tell me at once
and plainly, what have I done to offend you and make you
so cold to me?"

Anne, looked round like a frightened hare for a chance to

escape, but seeing none, she seemed to control herself and
resume her usual icy composure with a great effort. "You
have done nothing to offend me," replied she coldly. "What
makes you think so?"

"Your whole air and manner," replied Jack frankly. "You

avoid me at all times as though my presence carried the
plague with it. You never speak to me if you can help it, and
I tell you freely, sister Anne, I cannot think it right. Even if I
have displeased you, it is not the part of a Christian to bear
malice. The Scripture rule is, 'If thy brother trespass against
thee, tell him his fault between him and thee alone.'"

"The Scripture!" said Anne, starting. "What do you know of

Scripture?"

"I know that much at all events, and so do you, because

Father William preached from it only last Sunday."

"I did not hear the sermon," replied Anne. "I was praying in
our Lady's Chapel. It would be well, brother, if you prayed
more and minded sermons less."
"And I cannot but think, sister, that it would be well for you,
not perhaps to pray less, but to seek instruction more."

"I seek instruction where sound teaching is to be found,"

said Anne, coloring. "I do not run after novelties and
novelty-mongers like Father William."

"You have no right to speak in that way of Father William,"

said Jack, coloring in his turn. "But we will let that pass.
One of two things I am sure of," he added, fixing his eyes
upon Anne; "either you think I have wronged you or that
you have wronged me. Which is it?"

Anne's color grew yet deeper and then faded to paleness.

She dropped her eyes, but did not speak.

"Anne, did you tell Father Barnaby that I was curious about
heretical books?" asked Jack.

"That is no affair of yours," replied Anne, trying to speak in

her usual tone, though she trembled visibly. "My
confessions are between my confessor and myself."

"In faith, it is my affair, and is like to be an affair of

moment, if your confessions are such as may bring me to
the stake," returned Jack. "Father Barnaby may be your
confessor, but he is not mine; and you have no right to talk
of my affairs to him."

Anne grew paler and paler. She sat silent for a moment, and
then whispered, "I could not help it."

"Could not help it," repeated Jack. "Could you not tell him
the truth, at least? When did I ever say to you that I would
like to read heretical books?"

"You said you would like to read the Bible," said Anne.
"And is the Bible an heretical book? Is not the Bible the
Word of God? And how then can it be heretical?"

"There is no use in going over all that again," returned

Anne. "You know as well as I that it is wrong and
presumptuous for lay and common people to desire to read
the Scripture. You know what comes of it."

"I know what will come of it one day, and that will be the
downfall and ruin of those who so presumptuously keep it
from them to whom it rightfully belongs," said Jack,
forgetting his prudence. He might have said more had not
Anne herself checked him.

"Jack, if you have any mercy on me or yourself, hush, and

say no more such things. You will not only destroy your own
soul, but mine, if you go on. If you knew all that I have
borne and am bearing for your sake, you would be more
pitiful to me."

"But why should you bear anything on my account, dear

Anne?" asked Jack, softened at once by his sister's look and
tone of distress.

"Because I would save you if it were possible," returned

Anne, weeping; "because I would—but oh, it is of no use!"
she sobbed, bursting into a flood of bitter tears. "I would
have saved the other. I would have saved Agnes, if a whole
life spent in prayer and penance would have done it—if it
would have availed for her even after ages spent in
purgatory; but all is of no use. Father Barnaby says she was
an incurable heretic, and as such doomed to hell without
remedy; and he says my love for one like her is a sin for
which all my penances will hardly atone. Oh, what shall I
do? What shall I do? Oh, if I could see any way of escape,
any ray of hope; but no, there is, there can be none!"
Jack hesitated a moment, and then came to his sister's
side. He felt that he must speak, that to keep silence would
be that denial of which Master Fleming had warned him to
beware at all hazards.

"Anne, believe me, there is another way, an easy and safe

way to mind and spirit, whatever it may be to the body in
these evil times," said he. "God is far, far more merciful
than you think. All these labors which are wearing out your
life are none of His appointing. They are but the cunning
devices of men. He hath provided a way by which we may
be saved, even by simple faith in His mercy through the
blood of His Son."

"Dear Anne, our Lord hath done all for us already. He hath
borne our sins in His own body on the tree; it is by His
stripes we are healed, and not by those we lay on
ourselves; the Scripture says so. They are the words of St.
Peter himself. He came into the world not to condemn, but
to save it, and whosoever believeth in Him hath everlasting
life and shall never come into condemnation. He is ready to
save, His ear is always open. Oh, dear Anne, come to Him—
see and know Him. Leave all these devices of men which
are separating you from your family, and driving you into
your grave, and be at peace."

Anne looked at her brother for a moment with wide-open

eyes as if she had seen a ghost. Then she said in a husky
whisper—

"What do you mean? Who has been saying these things to

you?"

"It is the Lord Himself who says them, Anne," replied Jack.
"He tells us so in His Word, that very word which supported
Agnes Harland when she was despitefully used for reading
and believing it. Anne, I am putting my life in your hands by
telling you these things; but I cannot see you suffering as
you are without trying to help you. Oh, sister, only read for
yourself—only hear—"

In his eagerness, he had thrown himself on his knees at his

sister's side and seized her hand.

Anne pushed him away.

"How dare you speak so to me?" she said angrily. "Is it not
enough then that you should destroy yourself without trying
to destroy me?"

"It is because I would save you that I speak. Only look for
yourself. Anne, I tell you, as sure as you are alive, there is
no other way of salvation but through faith in Christ. If your
merits were as great as those of St. Peter himself, they
could avail nothing so far as that is concerned. Our Lord has
Himself paid all the price of our redemption, and we have
but to accept it as a free gift at His hands. Oh, sister, the
way is so easy!"

"Easy! Yes, the way to hell is always easy," said Anne, with
bitterness. "It is the other way that is hard. How dare you
come bringing your heresies into this room where our
mother died? How dare you speak them to me who am the
promised bride of Christ? How dare you tell me that all my
prayers and penances are worth nothing in God's sight,
after all these years that I have striven to earn His favor
and love?"

Jack was silent for a moment, startled by Anne's burst of

passion so unlike her usual self-restraint.

Then he said gently, "His favor and love are yours already,
Anne, if you will but take them. They are a free gift. The gift
of God is eternal life through His dear Son."

"Oh, it is too hard—too hard," cried Anne, bursting into a

fresh passion of tears. "I have heard all these things before.
They rang in my ears for weeks and months after Agnes
was taken from me; and now, just as they had ceased to
haunt me day and night, you awaken the memory of them
again. I will go far away. I will to the nunnery again—to the
strictest order that I can find, and there in the darkest cell I
will—" Anne's words were choked by her sobs.

Jack, much distressed, would have taken her hand to

soothe her, but she repulsed him violently, and then as if
her strength were exhausted by the effort, she fell back
fainting in her chair.

At that moment, Sister Barbara opened the inner door

which communicated with her room.

"Hush, dear lad," said she, gently and quietly. "Help me to

lay your sister on the bed, and then leave her to me. She
will be better presently, poor thing."

"I fear I have been to blame," said Jack, as he lifted Anne in

his arms and felt shocked to discover how emaciated she
was. "I have distressed when I meant to help her."

"I know, I know," whispered the good nun. "Say no more,

but go and pray for her and all of us. I will bring her to
herself, and she will be better."
 CHAPTER XIII.

"THEY THAT SOW IN TEARS."

Jack left the house and went out to walk, feeling the need
of solitude to compose his thoughts. He was distressed at
his sister's condition, and a little frightened when he
thought of the way in which he had put himself in her
power; and yet, in considering the matter, he did not see
how he could have done otherwise. He was so deep in
thought that he started on being spoken to, as if a bolt had
fallen from the sky.

"A fair evening, my young brother," said Master Fleming.

"Yet you do not seem to be enjoying it greatly. Your eyes
are on the ground as if your thoughts were heavy."

"They are so in truth," said Jack. "I am right glad to meet

you, Master Fleming, and would willingly have your advice
and opinion on a grave matter."

"Both are at your service," said Master Fleming. "I trust

nothing unpleasant has chanced."

In reply Jack told him the whole story, to which Master

Fleming listened with grave attention.

"I cannot see that you have done wrong," said he at last.
"You might perhaps have used more caution, and yet
caution is not always best. You say no one heard you but
your sister?"
"Nobody unless Madam Barbara might have caught a few
words," replied Jack. "Her room is next my sister's. I hardly
think she could have done so, or she would not have spoken
so kindly and gently to me."

"What did she say?" asked Master Fleming.

"She bade me go pray for Anne and myself—pray for us all,

were her words, I think. She is always a kind lady; but,
methinks, as I remember it, there was an unusual
tenderness in her voice and glance."

"That is strange, if she did really overhear you," said the

merchant. "You do not think your sister would betray you?"

"Never, if she were left to herself," said Jack, warmly; "but

you see, there is just the rub. She will not be left to herself.
I have good reason to think that she has told tales of me
already, from what Father Barnaby said to me at Father
John's house in Holford."

"How was that?" asked Master Fleming.

Jack repeated the story, to which the merchant listened with

attention, laughing heartily as Jack recounted with
considerable humor his encounter with Father Barnaby, and
the way in which he had been thrown off the scent by
means of Horace and the Babylonian numbers.

"Well, my brother, you certainly owe Horace a debt of

gratitude," said he, when Jack had finished the story. "You
say you have not seen the priest since that time?"

Jack replied in the negative.

"I see nothing that you can do but to wait in hope and trust
for the result," said Master Fleming. "It may be that your
words will be blessed to your sister after all, and that she
may have grace to turn to the only source of comfort and
light. Poor young maid, my heart is sad for her. Meantime I
need not tell you to treat her with all kindness and
forbearance, and to pray earnestly for her."

"I never mean to be out of patience with her," said Jack,

"and yet she does anger me sometimes so that I can hardly
forbear speaking sharply to her—not for my own sake, but
for that of my father and my Cousin Cicely. She is such a
continual grief to them."

"There is nothing gained, but a good deal lost by that, my

young brother," said the merchant kindly. "I dare say your
good father does not lose patience with his unhappy
daughter."

"Not often," replied Jack. "He treats her always with the
greatest forbearance and kindness, puts up with all her
ways, and indulges her in everything; and yet she does not
seem to have the least notion of it."

"I dare say not; few people have," said the merchant dryly.
"But do you take pattern by your father, and remember that
you have a double call to exercise kindness and love. Let
me tell you what to do. When your patience seems like to
fail, do not dwell upon and aggravate in your own heart the
offence of your sister (as I know by my own experience one
is apt to do), but lift up your heart in prayer for her, and
then recall to mind your own offences against God, and His
gracious and free forgiveness, and remember our Lord's
saying, 'not till seven times, but till seventy times seven.'
Above all pray that your heart may be filled with love to
God and man, for therein lies the great remedy for sin in
every form."
"I will," said Jack, brushing the tears from his eyes. "Oh,
what shall I do for a counsellor when you are gone? I wish
you could abide with us always."

"That can hardly be," replied Master Fleming. "I must go

back to London before long. But I trust some friend will be
raised up to you."

"I wish I could go with you," said Jack. "It would be so

much easier to be good with you."

"It is not the part of a good soldier to choose the easiest

way," replied Master Fleming, smiling. "Besides, Jack, it is
usually a mistake to think that you could serve God and do
better in some other place than the one where He has put
you. It is this very error which has driven so many into the
cloister. Others it has led out into the dangers of the world,
for which they were wholly unfit. Many a one is sick of
home, and fancies he would do better in a wider sphere,
while he is failing in every relation of life in the place
assigned him by Providence. Be content where you are; few
lads have a better or more cheerful home, though all may
not be as you desire."

"I know that indeed," said Jack eagerly. "I should be a

villain to cherish discontent, while I have my father and
dear good Cousin Cicely to make much of me. I am rather
afraid my way will be made too soft and easy."

"Never fear," said Master Fleming. "That is a misfortune

which I venture to say never yet happened to one who was
honestly trying to serve God with all his heart. Our Father
loves to see His children happy, but He is sure to send them
all the crosses they need. Enjoy your peaceful sunshiny
home while it is yours, for these are threatening times, and
we may not long be left in peace. The sun shines just now,
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