Stop doing HIPAA the old way

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Health data security shouldn’t depend on outdated playbooks. But many organizations still approach HIPAA compliance as a periodic checklist or one-time documentation exercise. That mindset no longer matches the way threats evolve—or the way regulators operate.

Today, OCR (Office for Civil Rights) audits hone in on how well you implement and maintain the HIPAA Security Rule’s safeguards over time. And with recent attention on ransomware, data breaches, and lapses in access control, healthcare organizations and their business associates can’t afford a static or manual approach.

HIPAA compliance in 2024 requires more than meeting minimum standards. It demands a security-first mindset, practical risk management, and operational readiness. Let’s look at where HIPAA compliance comes from, why the traditional model falls short, and how leading organizations are preparing for a new era of health data protection.

The traditional approach to HIPAA compliance

Since its passage in 1996, HIPAA has centered on safeguarding protected health information (PHI). For most covered entities and business associates, the focus is the Security Rule and its requirement to ensure the confidentiality, integrity, and availability of electronic PHI (ePHI).

Historically, HIPAA compliance has been documentation-heavy and infrequent. Many organizations interpreted the rules as a blueprint for a binder: static policies, annual risk assessments, and scheduled training. Compliance duties often fell to small teams juggling security, privacy, and legal roles.

Assessments were often performed manually. Teams compiled evidence using spreadsheets, screenshots, and file shares. Risk analyses might have been conducted once a year—if that—without follow-up or tracking of mitigation steps.

Audit preparation was reactive, not proactive. When OCR sent a notification, organizations scrambled to locate policies, generate reports, and rationalize controls. Given just 10 business days to submit documents, those relying on disorganized files and stale documentation found themselves exposed.

This approach might have been adequate when cyber threats were rare, cloud migration was limited, and enforcement sporadic. That’s no longer the case.

The real-world challenges organizations face

Today, HIPAA compliance teams face an environment with stronger regulatory expectations, evolving threats, and increasing operational complexity. The old model breaks down quickly under this pressure.

Risk analysis remains a major gap. According to OCR’s own audit reports, the most common deficiency—year after year—is organizations failing to conduct “accurate and thorough” risk analyses. Some do not perform one at all. Others struggle to define scope, document vulnerabilities, or revisit results over time.

Ad hoc processes hinder visibility. Teams lose track of which controls are implemented, which are in progress, and which have supporting documentation. When an incident occurs or an audit hits, leaders lack the visibility to respond with confidence.

Manual work slows you down. Gathering evidence from dozens of systems takes time—often pulling staff away from their primary responsibilities. Without automation, compliance becomes a burden that’s both inefficient and error-prone.

There is no “HIPAA certification.” Unlike some other frameworks, HIPAA does not provide or recognize a formal certification. That means the burden is on your organization to demonstrate compliance continuously—not just pass a one-time test. A third-party attestation can help summarize your program, but it doesn’t substitute for maintaining controls and readiness every day.

OCR enforcement is active and rising. In 2024–2025, OCR is auditing 50 organizations with a focus on the Security Rule’s technical safeguards. These reviews aren’t check-the-box—they assess whether companies are appropriately managing threats such as hacking and ransomware. And enforcement actions with financial penalties often cite predictable failures: ineffective risk management, poor documentation, and outdated assessments.

When compliance is treated as occasional paperwork, critical gaps go unnoticed or unresolved until it’s too late.

What HIPAA compliance will look like in 2026

Regulators and security professionals agree: the future of HIPAA is proactive, risk-based, and aligned to modern cybersecurity standards.

Ongoing risk management is the foundation. The Security Rule already requires a process—not just a document. In recent guidance, OCR emphasizes continuous evaluation of new threats, operational changes, and mitigation efforts. By 2026, organizations will be expected to integrate HIPAA risk considerations into security programs, vendor assessments, and change management.

More alignment with NIST standards. The February 2024 release of NIST SP 800-66 Rev. 2 offers detailed guidance on implementing Security Rule safeguards. Alongside the HHS crosswalk to NIST’s Cybersecurity Framework, these tools create a path for organizations to modernize HIPAA programs using widely adopted cybersecurity practices.

Tech-enabled compliance will be the norm. Platforms that automate evidence collection, track risks, and orchestrate tasks across departments remove friction from compliance. This isn’t just about saving time—it’s about delivering trustworthy, audit-ready documentation with fewer gaps.

Multi-framework efficiency will matter. As more organizations pursue frameworks like HITRUST, ISO 27001, or SOC 2 alongside HIPAA, the ability to map controls across standards becomes essential. Doing so reduces duplication and gives security leaders a clearer picture of their entire risk posture.

HIPAA compliance in 2026 will be built into operations—not bolted on. It will require tools, processes, and partners that enable an efficient and resilient program.

How Thoropass transforms HIPAA compliance

Thoropass helps organizations stop doing HIPAA the old way by delivering a compliance program that simplifies, strengthens, and scales.

Automated evidence means less manual work. Native integrations connect directly to your systems to continuously collect relevant data. That keeps your controls up to date and your documentation centralized—no more chasing screenshots or piecing together access logs.

Risk analysis and tracking made actionable. Thoropass guides your team through risk identification, evaluation, and mitigation. You can track ongoing efforts, assign responsibilities, and deliver clear evidence that aligns with OCR’s expectations.

Policy templates and workflows ensure completeness. Built-in templates and task orchestration make it easy to manage everything from security policies to breach response planning. That means your documentation isn’t just compliant—it’s current and maintainable.

Clear alignment with NIST and other frameworks. Thoropass structures HIPAA controls based on authoritative guidance, including NIST SP 800-66. Your HIPAA efforts can fit into a larger, harmonized compliance strategy—reducing redundancy and increasing confidence.

Third-party attestation adds credibility. While HIPAA doesn’t offer certification, your organization may choose to undergo a third-party review. Thoropass can support that effort with auditor-tested evidence, independent assessments, and a summarized compliance report. And because our auditors never grade their own work, you get a clear, defensible result.

Where to go from here

HIPAA compliance isn’t going away—but the way you approach it can, and should, evolve. The old model of static documents and reactive audits doesn't protect patient data or reduce risk.

A modern HIPAA program runs continuously. It integrates with your technology stack. It enables fast, accurate responses during audits. And it scales as your organization grows.

Compliance shouldn’t slow you down. Thoropass helps you keep your HIPAA security posture strong with automation, guidance, and audit-ready documentation—so you’re not just compliant today, but always prepared for what’s next.

Ready to upgrade your HIPAA compliance program? Schedule a discovery session with Thoropass and take the first step toward a smarter, stronger approach.