09/22/2025
The healthcare regulatory landscape is shifting. In late 2024 and early 2025, the U.S. Department of Health and Human Services (HHS) released a Notice of Proposed Rulemaking (NPRM) to update the HIPAA Security Rule — changes that will significantly raise the bar for protecting electronic protected health information (ePHI).
Key Proposed Changes:
- Elimination of the “Addressable” / “Required” distinction
- Mandatory Multi-Factor Authentication (MFA) for access points to ePHI.
- Expanded risk assessments including technology asset inventories, network mapping, and more explicit guidelines for identifying and managing risks.
- Stronger encryption requirements for data at rest and in transit, with fewer exceptions.
- More rigorous incident response, backup, and disaster recovery practices, including written and tested plans with defined timeframes.
What This Means for Healthcare Organizations:
- Compliance will require proactive investment. Entities will need to review and likely overhaul existing security controls, policies, vendor contracts, and technical architectures.
- Business associates and vendors will face increased scrutiny. Any partner handling ePHI will be expected to meet these enhanced requirements.
- Audits and enforcement are likely to become more intense. With clearer rules and fewer exceptions, regulators will expect concrete evidence of compliance.
- Operational impact will be significant. Inventorying assets, mapping data flows, implementing MFA, and updating encryption standards across systems will take time and resources.
These changes represent real opportunity for those who act now. At Digital Sentry, we help healthcare providers and their vendor networks not only understand these updated HIPAA requirements, but build programs to meet them: gap analyses, policy redesign, pe*******on testing, and vendor risk management. The organizations that lead in compliance will also lead in reputation, trust, and resilience.