Primary Justifications for HIPAA Security Rule Changes by OCR:
1. Evolving Cybersecurity Threat Landscape
The OCR emphasized that healthcare entities are facing increasingly sophisticated cyberattacks – such as ransomware, phishing, and data breaches targeting electronic protected health information (ePHI) , necessitating modernization of the Security Rule. This is especially critical, given how much the HITECH Act accelerated universal adoption of electronic health record systems (EHR/EMR) and enabled digital exchange of patient data among providers and health ecosystem intermediaries (HEIs).
2. Increased Reliance on Connected Technologies
The unfortunate downside of interoperable technologies is the proliferation of network-connected medical devices, clinical equipment, ambient AI, and cloud services – that have greatly expanded the attack entry points for providers. In what may prove to be the most challenging compliance update, the new rule greatly expands the categorization of these ePHI technologies and ePHI technology assets, to more appropriately encompass the evolving risks associated with next-gen solutions.
3. Closing Gaps in Security Implementation
The OCR found that reasonable implementation safeguards are not being consistently adopted across entities, nor across their business associate partners (the vendors who provide these critical systems and technologies). Accordingly, the ambiguity of what was previously considered “addressable” versus what will now be “required” makes all security implementation standards mandatory with far fewer exceptions.
4. Improving Incident Response and Resilience
Recent incidents have revealed deficiencies in how organizations detect, respond to, and recover from cyber incidents. Thus, rule revisions will mandate stronger incident response planning, expanded applications of multi-factor user authentication, and more frequent vulnerability/penetration assessments. By combining enhanced contingency planning with asset inventories and network-wide mapping of ePHI data flow, entities can gain comprehensive visibility into their data infrastructure, enabling more effective control and faster recovery from cyber incidents.
5. Encouraging a Culture of Security and Accountability
The OCR noted the need for organizations to adopt a proactive cybersecurity mindset – integrating ePHI protection into acquisition and operations – rather than treating it as an afterthought. The rules promote risk management and shared accountability that now extends to group health plans and business associate vendors/suppliers. Today many of these technology vendors and partners are overlooked.
6. Harmonizing with Other Federal Cybersecurity Initiatives
The OCR intentionally aligned new HIPAA rule requirements with established National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF). This congruence rewards healthcare providers who have been proactively adopting more mature digital resilience plans through NIST-based practices already. The crossover also encourages secure data interoperability between healthcare entities and their federal, state, and public-sector/education agency partners. The state of Ohio has formally adopted NIST as its cybersecurity baseline, and since 2018, the Ohio Data Protection Act (ODPA) has offered safe harbor protections to businesses implementing NIST CSF, ISO 22301 (for business continuity), and CIS Controls (for tactical execution).
What Does this all mean?
The HIPAA Security Rule has seen few updates since 2003, and it’s been over a decade since the HITECH Act first addressed the shift from paper-based clinical processes to electronic PHI workflows. Since then, the systems and technologies integrated with ePHI have surged. Telehealth, hybrid care models, smart medical equipment, and connected clinical devices now form the backbone of modern care delivery; supported by cloud infrastructure and increasingly optimized by AI. The pandemic propelled this transformation, but the 2030 labor-force inversion will only accelerate/necessitate it further. As ePHI now moves through more endpoints, networks, and more systems than ever before, the risk landscape is evolving – so the standards need to as well.
How Can We Help Your Organization?
At Obviam, we begin by helping organizations understand where they currently stand. We start with gap analyses aligned to the more mature security frameworks – NIST CSF, ISO 22301, and CIS Controls – translating federal expectations into practical, prioritized actions, and helping guide you to where HIPAA rule changes are about to go. From there, we provide vulnerability assessments, penetration testing, and support implementation of digital observability, zero-trust, and other critical protection platforms – translating all the compliance jargon and IT anagrams into less-exposed and continuously-improving threat defense.
We understand that nearly half of all providers are still relying on reactive data strategies, largely due to the budget constraints, which are consistently cited as the #1 barrier to investing in digital resilience. But that position will be unsustainable once the security baselines in the HIPAA security rules evolve. Together, we can help you quantify material risk, prioritize mandated investments, write the new compliance policies, and develop a roadmap that strengthens security posture, ensures continuity of care, and makes every dollar work harder against today’s bad actors.
At Optimized IT (OIT), we excel in reducing the burden of day-to-day IT demands and infrastructure management, so that your IS teams can stay focused on advancing data strategy, infrastructure resiliency, and holistic security. From device patching and endpoint monitoring to user provisioning and ticket response, we can assume many of the foundational IT tasks that detract from more urgent and valuable work.
At MOM, we ensure that print, scanning, and document management workflows are in full security framework alignment. As a business associate, MOM has longed deployed ePHI hardware, management software, and break/fix service programs in healthcare environments. But we have also found we are one of the most overlooked type-of -vendors that the new HIPAA security rule is seeking to place greater scrutiny upon. The good news is, we are prepared with fully compliant technologies and processes – ensuring that no endpoint, physical or digital document, or device – remains a blind spot in your broader cybersecurity strategy.