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HIPAA Regulatory Updates

Stay current with the latest HIPAA changes, OCR guidance, and enforcement trends.

Action Required: 2026 Privacy Rule

New NPP requirements take effect February 2026. Update your Notice of Privacy Practices before the deadline.

UpcomingHigh ImpactFebruary 2026

2026 HIPAA Privacy Rule Updates

Major changes to Notice of Privacy Practices, patient access rights, and reproductive health information protections.

The HHS Office for Civil Rights has finalized significant updates to the HIPAA Privacy Rule, taking effect February 2026.


Key Changes:


Notice of Privacy Practices (NPP):

  • Clearer, plain-language requirements
  • New required disclosures about patient rights
  • Must explain electronic access options
  • Updated distribution requirements

  • Patient Access Rights:

  • Strengthened right of access provisions
  • Reduced fees for electronic copies
  • 15-day response requirement (down from 30)
  • Third-party access designations

  • Reproductive Health Information:

  • New protections for reproductive healthcare records
  • Limits on disclosures for investigation/litigation
  • Attestation requirements for certain disclosures

  • Action Required:

  • Update your NPP before February 2026
  • Review access request procedures
  • Train staff on new requirements
  • Update privacy policies
  • CurrentHigh ImpactJanuary 2026

    OCR Enforcement Trends & Focus Areas

    Record enforcement activity in 2025 with continued focus on risk assessments, patient access, and small practices.

    The Office for Civil Rights continues aggressive HIPAA enforcement, with particular focus on several key areas.


    2025 Enforcement Highlights:

  • Record number of enforcement actions
  • Increased focus on small and medium practices
  • Right of Access Initiative continues
  • HIPAA Security Rule Audit Program expansion

  • Current Focus Areas:


    Risk Assessments:

  • Most common deficiency cited
  • Required regardless of practice size
  • Must be documented and updated regularly
  • Addressable specifications still require documentation

  • Patient Access:

  • 40+ enforcement actions under Right of Access Initiative
  • Settlements ranging from $3,500 to $200,000+
  • 30-day compliance deadline (15 days under 2026 rules)

  • Business Associate Oversight:

  • Covered entities responsible for BA compliance
  • BAA requirement strictly enforced
  • Subcontractor chain requirements

  • Ransomware Response:

  • Investigations following ransomware attacks
  • Breach notification compliance scrutinized
  • Security measures examined post-incident
  • CurrentMedium ImpactDecember 2025

    HHS Healthcare Cybersecurity Guidelines

    New voluntary cybersecurity performance goals for healthcare organizations.

    HHS has released Healthcare and Public Health (HPH) Cybersecurity Performance Goals to help healthcare organizations prioritize cybersecurity investments.


    Essential Goals (10 items):

  • Email security (DMARC, anti-phishing)
  • Basic cybersecurity training
  • Strong authentication (MFA)
  • Basic endpoint protection
  • Vulnerability management
  • Incident planning
  • Network segmentation
  • Data backup
  • Third-party risk management
  • Asset inventory

  • Enhanced Goals (10 items):

  • Advanced email protection
  • Centralized log management
  • Cybersecurity testing
  • Insider threat programs
  • Configuration management
  • Enhanced incident response
  • Network monitoring
  • Supply chain security
  • Advanced authentication
  • Centralized security operations

  • Important Note:

    While currently voluntary, these goals may become part of future Medicare Conditions of Participation or other regulatory requirements.

    CurrentMedium ImpactNovember 2025

    2025 Healthcare Breach Statistics

    Healthcare remains the most targeted industry with record breach costs and ransomware attacks.

    Annual breach statistics reveal continued cybersecurity challenges for healthcare.


    2025 Key Statistics:

  • 700+ large breaches reported (500+ individuals)
  • 150+ million individuals affected
  • Average breach cost: $10.93 million
  • Average time to identify breach: 200+ days
  • Healthcare: #1 targeted industry for 13th year

  • Top Breach Causes:

  • Hacking/IT Incidents (75%)
  • Unauthorized Access (15%)
  • Theft/Loss (7%)
  • Other (3%)

  • Ransomware Trends:

  • 50%+ of healthcare organizations attacked
  • Average ransom demand: $1.5 million
  • Average downtime: 21 days
  • Many organizations paying despite guidance

  • Implications:

  • Risk assessment more critical than ever
  • Cybersecurity investment essential
  • Incident response planning required
  • Business associate oversight needed
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