Best Practices to Assess and Address Security Risks to ePHI
Protecting electronic protected health information (ePHI) demands a disciplined, continuous approach. This guide outlines best practices you can apply to assess and address security risks to ePHI while strengthening compliance and patient trust.
You will learn how to perform risk analyses, build reliable inventories, enforce precise access, encrypt data effectively, harden networks, train people well, and respond confidently to incidents.
Conduct Risk Assessments Regularly
Why frequency matters
Threats evolve, systems change, and new partners join your ecosystem. Regular risk assessments and documented risk analyses reveal where ePHI is exposed and which safeguards deserve priority funding and attention.
How to execute
- Define scope and objectives: include all systems, data stores, workflows, and third parties that create, receive, maintain, or transmit ePHI.
- Identify assets and data flows: map where ePHI resides and moves to support later control selection and testing.
- Perform vulnerability assessments: scan, validate, and rate technical and process weaknesses that could affect confidentiality, integrity, or availability.
- Evaluate likelihood and impact: use a consistent methodology to build a risk register with owners, remediation steps, and timelines.
- Treat and track: implement fixes, verify completion, and retest to confirm risk reduction.
- Trigger reassessments: repeat after major changes, incidents, or audit findings, not just on a calendar.
Documentation and oversight
Maintain evidence for HIPAA security audits, including assessment procedures, results, decisions, and approvals. Escalate high risks to leadership and ensure budget, sequencing, and success metrics are clear.
Maintain Comprehensive Data Inventories
Build a living catalog
You cannot defend what you cannot see. Create a current inventory of systems, applications, databases, devices, and vendors that touch ePHI, and classify data sensitivity by context.
What to capture
- Data elements in scope (e.g., identifiers, clinical notes, images) and retention requirements.
- Locations of ePHI: on-premises, endpoints, cloud services, backups, and removable media.
- Data flows: ingestion, processing, storage, sharing, and deletion paths.
- Owners, custodians, and business purposes for each dataset.
Automation helps
Use discovery tools, DLP, and configuration management to detect new stores and shadow IT. Accurate inventories make access decisions, encryption coverage, and vulnerability assessments far more effective.
Implement Robust Access Controls
Design for least privilege
Grant only the access people need to perform their duties. Role-based access controls align permissions to job functions, simplify provisioning, and reduce errors.
Core practices to adopt
- Strong authentication: require MFA for all users handling ePHI and for administrators.
- Joiner-mover-leaver automation: tie provisioning to HR events to prevent orphaned accounts.
- Privileged access governance: enforce break-glass workflows, session recording, and time-bound elevation.
- Regular access reviews: schedule periodic certifications and remove unused or excessive rights.
- Segregation of duties: prevent conflicts that enable unauthorized viewing or alteration of records.
Apply Strong Encryption Protocols
Protect data at rest and in transit
Enable data-at-rest encryption on servers, databases, storage volumes, backups, and endpoints. Use modern TLS for all data in transit, including APIs, email gateways, and remote access.
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- Centralize key management with rotation, separation of duties, and hardware-backed protection where feasible.
- Encrypt backups and archives; test restores to confirm keys and procedures work under pressure.
- Secure mobile devices and removable media with full-disk encryption and remote wipe capabilities.
Strengthen Network Security Measures
Reduce the blast radius
Segment networks to isolate clinical systems, administrative functions, and third-party connections. Apply zero-trust principles so every access is authenticated, authorized, and continuously verified.
Detection and prevention
- Deploy next-generation firewalls and intrusion detection systems; integrate alerts into a centralized SIEM.
- Harden remote access with MFA, device posture checks, and least-privilege tunneling.
- Patch promptly and automate configuration baselines to eliminate known weaknesses.
- Protect email and web channels with advanced filtering, sandboxing, and DMARC enforcement.
Provide Employee Security Training
Make people your strongest control
Targeted, role-aware training turns staff into active defenders of ePHI. Teach how to handle records appropriately, recognize social engineering, and report issues quickly.
Program essentials
- Onboarding and annual refreshers, with just-in-time microtraining for high-risk workflows.
- Phishing simulations and measurable goals to improve reporting rates and reduce click-throughs.
- Scenario-based exercises for clinicians, revenue cycle teams, and IT staff.
- Clear, no-blame reporting channels to accelerate containment when something seems wrong.
Develop Incident Response Strategies
Plan, practice, and improve
Establish an incident response plan covering identification, containment, eradication, recovery, and lessons learned. Define roles, on-call rotations, decision thresholds, and authority to act.
Operational readiness
- Maintain forensic readiness: centralized logging, synchronized time, and evidence handling procedures.
- Create playbooks for ransomware, lost devices, insider misuse, and vendor breaches.
- Set recovery objectives and test backups to validate restoration speed and data integrity.
- Coordinate contingency plan notifications so stakeholders, partners, and patients receive timely, accurate information.
Compliance and follow-through
After containment, complete root-cause analysis, update controls, and document actions for regulators and leadership. Use findings to refine risk analyses and prepare for subsequent HIPAA security audits.
In summary, sustained success comes from disciplined assessments, complete inventories, precise access, comprehensive encryption, layered network defenses, engaged people, and a battle-tested response capability—working together to reduce real-world risk to ePHI.
FAQs
What are the key steps in assessing security risks to ePHI?
Start by inventorying assets and mapping ePHI flows. Identify threats and perform vulnerability assessments. Score likelihood and impact to build a risk register, assign owners, implement treatments, verify results, and monitor continuously with clear triggers for reassessment.
How can organizations ensure effective access controls for ePHI?
Adopt role-based access controls with least privilege, require MFA, automate joiner-mover-leaver workflows, and enforce privileged access safeguards. Review access regularly, log activity, and remove unused rights quickly to keep exposure minimal.
What role does employee training play in protecting ePHI?
Training reduces human-driven risk by improving phishing resistance, correct data handling, and rapid incident reporting. Role-specific, scenario-based modules and ongoing microlearning build habits that complement technical controls and strengthen overall resilience.
How often should security audits be performed to maintain HIPAA compliance?
Conduct formal security audits at least annually and after major changes or incidents. Supplement with ongoing monitoring, periodic access reviews, frequent vulnerability scanning, and regular tabletop exercises to ensure controls remain effective and evidence-ready.
Ready to assess your HIPAA security risks?
Join thousands of organizations that use Accountable to identify and fix their security gaps.
Take the Free Risk Assessment