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Medical practices are evolving constantly. New vendors, new workflows, staff working remotely, and other tweaks change how practices operate on a daily basis. Most of these changes are made for good reasons. However, few are made with HIPAA in mind.
That gap is where risks accumulate.
Adding a cloud-based scheduling tool, switching to a different patient messaging platform, bringing on a new billing vendor - none of these feel like security decisions in the moment. But each affect how protected health information moves, who can access it, and where it ends up. A risk analysis that was accurate 18 months ago may not reflect how the practice actually operates today.
The Office for Civil Rights recently announced settlements connected to ransomware investigations, a pattern that underscores what regulators have been signaling for years: they want to see documentation that healthcare organizations have genuinely thought through their risks, and not just filed paperwork.
For most practices, this doesn't require a sophisticated security program. It requires honest answers to a handful of questions:
- Who can access patient records?
- Are staff connecting remotely through secured tools?
- When did someone last test the backups?
- Are business associate agreements current for every vendor?
- Have employees been trained to recognize phishing attempts?
The harder question is whether the practice has a process for revisiting these things when something changes. A risk analysis written at the start of the year can go stale quickly. New software, staffing changes, even shifts in how patients communicate. Any of the aforementioned changes can introduce vulnerabilities that weren't there before.
Keeping the analysis current isn't just about regulatory compliance. It's one of the more practical things a practice can do to reduce the likelihood of a disruptive incident and to demonstrate, if questions ever arise, that patient information was taken seriously.
Source: Rickard & Associates, one of TPA's Affiliate Partners, provides extensive legal knowledge on a variety of business issues to TPA members. For more information, contact Lori-Ann Rickard at info@larlegal.com, (586) 498-0600.
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