HHS Cybersecurity Performance Goals (HPH CPGs): What They Are and How to Meet Them

Overview of HHS Cybersecurity Performance Goals

HHS Cybersecurity Performance Goals (HPH CPGs) define prioritized, outcome-based practices that healthcare and public health organizations can use to reduce cyber risk. They translate federal cybersecurity standards into practical actions you can implement across clinical, business, and technical environments.

Designed to be technology-neutral, the HPH CPGs emphasize measurable outcomes over specific tools. They help align cybersecurity governance with patient safety, healthcare data protection, and operational resilience for hospitals, clinics, payers, public health agencies, and health IT vendors.

The goals typically group into “baseline” safeguards every entity should implement and “enhanced” safeguards for more mature programs. This structure lets you scale improvements based on risk, size, and resource constraints while maintaining consistent incident response protocols and continuous monitoring processes.

Purpose of HPH CPGs

The HPH CPGs exist to reduce the likelihood and impact of cyber incidents that disrupt care delivery or compromise protected health information. They focus on safeguarding clinical operations so that critical services remain available during ransomware attacks, outages, and third‑party failures.

They also create a shared language for executives, boards, and security teams. By aligning with risk management frameworks, the goals support investment decisions, define accountability, and clarify minimum expectations for access control mechanisms, data protection, and incident response protocols across the healthcare ecosystem.

Key Areas Covered by HPH CPGs

Identity, Access, and Device Security

• Strong authentication (e.g., multifactor) and least-privilege models for workforce, vendors, and admins.
• Privileged access management and routine access reviews to constrain exposure.
• Asset inventory for IT, OT, and medical devices, with secure configuration baselines.

Network Resilience and Zero Trust

• Segmentation to isolate critical systems and medical devices from internet-facing networks.
• Secure remote access, microsegmentation where feasible, and rapid containment procedures.

Vulnerability, Patch, and Threat Management

• Risk-based patching SLAs, compensating controls for legacy devices, and exploit-driven prioritization.
• Endpoint detection and response with 24/7 alert triage and threat hunting for continuous monitoring processes.

Data Protection and Recovery

• Encryption in transit and at rest, data loss prevention, and disciplined key management.
• Immutable, offline, and tested backups with time-bound recovery objectives for clinical systems.

Application, Cloud, and Third-Party Security

• Secure software development lifecycle, SBOM usage, and rigorous change control.
• Cloud configuration baselines, logging, and shared-responsibility clarity with vendors.
• Third-party risk governance, contractual security clauses, and continuous performance monitoring.

Incident Response and Business Continuity

• Documented incident response protocols with defined roles, on-call coverage, and escalation paths.
• Tabletop exercises that include downtime procedures for EHR access, imaging, and lab operations.

Governance, Training, and Culture

• Board-visible cybersecurity governance, policy management, and budget oversight.
• Role-based security awareness and phishing resistance training tailored to clinical workflows.

Implementation Guidance for Healthcare Entities

1) Assess and Prioritize

• Map existing controls to the HPH CPGs and your chosen risk management frameworks to identify gaps.
• Prioritize remediation by patient safety, downtime risk, data sensitivity, and regulatory exposure.

2) Establish Governance and Ownership

• Designate an accountable executive and cross-functional steering group to drive cybersecurity governance.
• Integrate cyber risk into enterprise risk registers and board reporting cadences.

3) Execute High-Impact Quick Wins

• Enable multifactor authentication for remote access and privileged accounts.
• Deploy EDR across servers and endpoints; tune detections and response playbooks.
• Harden email with anti-phishing controls and implement DMARC/DKIM/SPF.
• Stand up immutable, offline backups and test restoration of critical clinical apps.

4) Mature Core Capabilities

• Implement access control mechanisms such as least privilege, JIT access, and periodic access reviews.
• Adopt network segmentation for medical devices; apply virtual patching where vendor updates are limited.
• Stand up continuous monitoring processes: centralized logging, UEBA, and threat intelligence ingestion.

5) Secure the Supply Chain

• Use standardized questionnaires, attestations, and performance SLAs to manage vendors.
• Require breach notification terms, minimum control baselines, and evidence of testing.

6) Test, Measure, and Improve

• Run periodic tabletop and technical exercises (phishing, recovery, segmentation validation).
• Track metrics: MFA coverage, critical patch MTTR, EDR deployment rate, backup test success, and incident containment times.

Compliance and Reporting Requirements

The HPH CPGs are performance goals rather than prescriptive regulations. You should treat them as a prioritized roadmap that complements existing obligations (for example, HIPAA Security Rule and relevant state laws) and aligns with federal cybersecurity standards and recognized best practices.

To evidence conformance, build an auditable trail: current policies, standards, risk assessments, asset inventories, configuration baselines, training records, incident logs, and test results. Maintain mappings from HPH CPGs to your risk management frameworks to show traceability from goal to control to metric.

Suggested program and board metrics

• MFA adoption for privileged and remote users.
• Mean time to patch critical vulnerabilities and exceptions approved.
• EDR/AV coverage and blocked high-severity events.
• Backup immutability, frequency, and restoration success rates.
• Vendor risk assessments completed and overdue remediations.
• Incident response drill frequency and mean time to contain.

Reporting should occur on a defined cadence to executive leadership and the board, with risk acceptance decisions documented. Where contracts or grant programs reference the HPH CPGs, retain attestations and third-party assessments that validate your control posture.

Benefits of Meeting HPH CPGs

• Improved patient safety and continuity of care during cyber disruptions.
• Reduced breach likelihood and impact through layered healthcare data protection.
• Stronger negotiating position with vendors and cyber insurers.
• Operational resilience and faster recovery from ransomware and outages.
• Clearer accountability via cybersecurity governance and measurable outcomes.
• Future-readiness as regulations, payers, and partners reference common security baselines.

Challenges in Meeting HPH CPGs

• Resource constraints and competing clinical priorities.
• Legacy systems and medical devices with limited patchability.
• Staffing shortages in security operations and engineering.
• Complex vendor ecosystems and inconsistent third‑party assurances.
• Data sprawl across EHRs, imaging, cloud apps, and endpoints.
• Change management and clinician workflow impacts.

Practical ways to overcome challenges

• Phase work in 30/60/90‑day sprints focused on the highest-risk gaps first.
• Leverage managed security partners to extend monitoring and incident response coverage.
• Use compensating controls (network isolation, JIT access) for unpatchable devices.
• Integrate training into daily workflows and tailor content to clinical roles.

Conclusion

The HPH CPGs offer a clear, risk-based path to protect patients and sustain operations. By aligning governance, access control mechanisms, incident response protocols, and continuous monitoring processes, you can strengthen resilience while demonstrating disciplined, outcomes-driven cybersecurity management.

FAQs

What are the main objectives of HPH CPGs?

The objectives are to minimize patient safety risks, reduce the frequency and impact of cyber incidents, protect sensitive data, and strengthen operational resilience. They provide prioritized, outcome-based guidance that maps to federal cybersecurity standards and recognized risk management frameworks.

How do healthcare organizations implement HPH CPGs?

Start with a gap assessment, prioritize remediation by clinical and operational risk, execute quick wins (MFA, EDR, backups), mature core capabilities like segmentation and logging, tighten third‑party oversight, and measure progress with clear KPIs reported through cybersecurity governance structures.

What are common challenges in meeting HPH CPGs?

Typical challenges include limited budgets, legacy medical devices, staffing shortages, complex vendor ecosystems, and data sprawl. Phased roadmaps, managed services, compensating controls, and role-specific training help you overcome these barriers without disrupting care.

How is compliance with HPH CPGs measured?

Compliance is demonstrated through documented policies and controls, evidence of testing and exercises, and metrics such as MFA coverage, patching timeliness, EDR deployment, backup restore success, vendor risk remediation, and incident containment times. Many organizations also maintain formal mappings to risk management frameworks for auditability.