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Silver Fox Consulting

Compliance / HIPAA

Protect patient data and meet the HIPAA Security Rule.

Healthcare organizations are a leading target for ransomware, and an attack can take clinical systems offline as well as expose patient records. The HIPAA Security Rule requires covered entities and their business associates to protect electronic protected health information (ePHI) and to understand the risks to it.

We help hospitals, clinics, health tech companies and their vendors run a proper risk analysis, fix what it finds and document the program in a way that holds up if the Office for Civil Rights comes asking.

At a glance

Regulator
HHS Office for Civil Rights (OCR)
Applies to
Covered entities and business associates that handle ePHI
Core requirement
An accurate and thorough risk analysis, followed by risk management
Safeguards
Administrative, physical and technical
Texas
The Texas Medical Records Privacy Act adds state requirements

HIPAA

Risk analysis is where most programs fall short

When OCR investigates a breach, one of the first documents it asks for is the risk analysis. A missing, outdated or superficial risk analysis is one of the most common problems cited in OCR enforcement actions.

Texas adds its own layer. The Texas Medical Records Privacy Act, often called HB 300, applies to a wider group of organizations than HIPAA and has its own training and disclosure rules. We help you account for both.

How we help

01

Security Rule risk analysis

The document regulators ask for first.

  • Inventory of systems that create, receive, store or transmit ePHI
  • Threat and vulnerability identification
  • Likelihood and impact ratings
  • Documentation aligned with HHS guidance
  • Risk management plan
02

Safeguard implementation

Put the administrative, physical and technical controls in place.

  • Access controls and MFA
  • Audit logging and review
  • Encryption at rest and in transit
  • Backup, disaster recovery and emergency mode operations
  • Device and media controls
  • Workforce security training
03

Business associates

Security for vendors and the vendors you rely on.

  • Business associate inventory
  • Vendor security reviews
  • Support with business associate agreement reviews
  • Security programs for health tech companies selling to providers
04

Ransomware readiness

Keep patient care going if systems go down.

  • Backup isolation and recovery testing
  • Clinical downtime procedures
  • Tabletop exercises with clinical and IT leadership
  • Incident response and breach notification planning

Legal questions go to counsel

We handle the security side of HIPAA compliance. Questions about breach notification obligations, business associate agreements and the Privacy Rule belong with your legal counsel, and we work closely with counsel during incidents.

FAQ

Frequently asked questions

How often should we update our HIPAA risk analysis?

The Security Rule does not set a fixed schedule, but it expects the risk analysis to stay current. In practice that means reviewing it at least once a year and whenever something significant changes, such as a new EHR, a move to the cloud or an acquisition.

Is there an official HIPAA certification?

No. HHS does not certify organizations as HIPAA compliant. Some vendors sell certificates, but they carry no regulatory weight. What matters is a documented risk analysis, a working security program and evidence that you follow it.

Does HIPAA apply to our health tech startup?

If you create, receive, maintain or transmit protected health information on behalf of a covered entity, you are likely a business associate and the Security Rule applies to you directly. Your customers will usually ask you to sign a business associate agreement.

Find out where you stand on HIPAA.

A readiness review shows what an assessor would find today and what it will take to close the gaps.