HIPAA compliance is not static. Each year brings new enforcement priorities, updated guidance, emerging threats, and evolving regulations. For healthcare providers in 2025, the compliance landscape has shifted significantly due to proposed rulemaking, heightened enforcement, and lessons learned from major breaches. Staying ahead of these changes is essential to protecting patient data and avoiding costly penalties. This article covers what healthcare providers must know and act on in 2025.
The Proposed HIPAA Security Rule Update
In late 2024, the Department of Health and Human Services (HHS) published a Notice of Proposed Rulemaking (NPRM) to update the HIPAA Security Rule for the first time in over a decade. While the final rule is still pending as of early 2025, the proposed changes signal the direction of regulatory expectations. Key proposed changes include:
Eliminating the distinction between required and addressable specifications. Under the proposal, all implementation specifications would be required, removing the flexibility that allowed some organizations to avoid certain controls.
Explicit MFA requirement. Multi-factor authentication would be required for all access to ePHI, not merely recommended.
Mandatory encryption. Encryption of ePHI at rest and in transit would become universally required rather than addressable.
72-hour incident notification to HHS. Covered entities would need to notify HHS within 72 hours of activating their incident response plan, separate from the existing breach notification requirements.
Annual security audits. Organizations would be required to conduct compliance audits at least annually, with more frequent assessments for higher-risk areas.
Technology asset inventory. Maintaining a current, comprehensive inventory of all technology assets that create, receive, maintain, or transmit ePHI would be explicitly required.
Even though these rules are not yet final, prudent organizations should begin aligning their security programs with these proposed requirements now. Waiting for final rulemaking means scrambling to comply after the fact.
Recent Enforcement Actions and Lessons Learned
OCR enforcement actions in 2024 and early 2025 reveal clear patterns in what triggers investigations and where organizations fall short:
Risk analysis failures remain the top finding. The majority of settlements and corrective action plans cite absent, incomplete, or outdated risk analyses. OCR expects a thorough, organization-wide risk analysis that is updated regularly and drives actual security improvements.
Right of access violations continue. OCR has pursued dozens of enforcement actions under its Right of Access Initiative against providers who failed to provide patients with timely access to their records.
Ransomware investigations are increasing. OCR is investigating ransomware incidents not just as breaches but as potential HIPAA violations if organizations lacked reasonable safeguards.
State attorneys general are more active. Multiple states have pursued their own HIPAA-related enforcement actions, adding another layer of regulatory risk.
2025 Compliance Priorities for Healthcare Providers
Based on the regulatory environment, enforcement trends, and threat landscape, healthcare providers should prioritize the following in 2025:
Comprehensive Risk Analysis
If you have not conducted a thorough risk analysis in the past 12 months, this is your highest priority. The risk analysis must cover all systems that create, receive, maintain, or transmit ePHI, including cloud services, mobile devices, medical devices, and telehealth platforms. Document identified risks, your planned mitigations, and your timeline for implementation.
MFA Deployment
Implement multi-factor authentication on all systems that access ePHI. Prioritize remote access, email, EHR systems, and administrative accounts. The proposed Security Rule update will make this mandatory, and the Change Healthcare breach demonstrated the catastrophic consequences of operating without MFA.
Incident Response Readiness
Review and test your incident response plan. Conduct a tabletop exercise simulating a ransomware attack that disrupts clinical operations. Ensure your plan addresses the proposed 72-hour notification requirement and that key personnel know their roles. Verify that your offline backups are current and restorable.
Compliance Checklist for 2025
Use this checklist to assess your current compliance posture:
Current, comprehensive risk analysis completed within the past 12 months
Risk analysis findings documented with mitigation plans and timelines
MFA implemented on all ePHI-accessing systems
Encryption applied to ePHI at rest and in transit
Complete technology asset inventory maintained and updated
All business associate agreements current and reviewed
Workforce training conducted within the past 12 months with documentation
Incident response plan documented, tested, and updated
Backup and recovery procedures tested with verified restore capability
Access controls reviewed with role-based permissions verified
Terminated user access revoked promptly across all systems
Physical safeguards assessed for all locations where ePHI is accessed
Patient right of access procedures documented and operational
Security policies reviewed and updated to reflect current operations
Preparing for the Future of HIPAA
The trajectory of HIPAA regulation is clear: requirements are becoming more specific, more prescriptive, and more rigorously enforced. The days of vague addressable specifications and infrequent audits are ending. Organizations that build robust, well-documented security programs now will be well-positioned when the updated Security Rule takes effect.
Bellator Cyber Guard helps healthcare providers navigate the evolving HIPAA landscape with practical, right-sized compliance solutions. From risk analyses and policy development to technical implementation and staff training, we provide the guidance and hands-on support that small and mid-sized practices need to stay compliant and secure. Contact us at guard@bellatorit.com to start your 2025 compliance assessment.
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