2026 HIPAA Security Rule Changes: What Every Medical Practice Must Know

The HIPAA Security Rule is getting its most significant update in over two decades. On December 27, 2024, the Department of Health and Human Services (HHS) released a Notice of Proposed Rulemaking that will fundamentally change how medical practices protect electronic protected health information (ePHI). If your practice isn't prepared, you could face substantial penalties and operational disruptions.

Why the HIPAA Security Rule Is Changing Now

The current HIPAA Security Rule was introduced in 2003 and last updated in 2013. In that time, healthcare has become a prime target for cybercriminals:

• Healthcare data breaches exposed over 32 million patient records in Q1 2026 alone
• Ransomware attacks now affect over 40% of US health systems
• The average cost of a healthcare data breach has surpassed $12 million
• 60% of hospitals experience disrupted patient care following ransomware attacks

HHS recognized that the existing "addressable" implementation standards allowed too much flexibility, and many healthcare organizations took that as permission to skip critical security measures. The new rule eliminates that ambiguity.

Key Changes in the 2026 HIPAA Security Rule

1. Mandatory Encryption (No More "Addressable")

The most significant change: encryption is no longer optional. Under the current rule, encryption is "addressable," meaning practices could document why they chose not to implement it. The new rule makes encryption of ePHI mandatory—both at rest and in transit.

What this means for your practice:

• All stored patient data must be encrypted using NIST-approved standards
• Email containing ePHI must use encryption
• Data transmitted between systems must be encrypted
• Proper encryption key management is required

2. Mandatory Multi-Factor Authentication (MFA)

MFA will be required for all systems accessing ePHI. No exceptions, no alternatives. Every user accessing your EHR, patient portal, or any system containing protected health information must authenticate with at least two factors.

3. Comprehensive Asset Inventory

You must maintain a complete, documented inventory of all systems, software, and devices that access ePHI. This inventory must be updated at least annually—or whenever your environment changes.

4. Enhanced Risk Assessments

Risk assessments must now be:

• Conducted every 12 months (minimum)
• Thoroughly documented with specific findings
• Designed to drive actionable security improvements
• Include vulnerability scanning and penetration testing

A checkbox compliance approach will no longer satisfy regulators. You need genuine security improvements, not just paperwork.

5. Network Mapping Requirements

The new rule requires documented network maps showing how ePHI flows through your systems. These maps must be updated at least annually and after any significant changes to your IT environment.

6. 72-Hour Recovery Requirement

Perhaps the most operationally challenging requirement: you must demonstrate the ability to restore critical systems within 72 hours following a security incident. This requirement directly addresses the reality that ransomware attacks have disabled some healthcare organizations for weeks.

7. Annual Business Associate Verification

A signed Business Associate Agreement (BAA) is no longer sufficient. You must obtain written verification—at least annually—that your business associates have actually implemented the required technical safeguards. This means auditing your vendors, not just trusting their signatures.

Compliance Timeline

HHS plans to finalize the new Security Rule in May 2026. Once finalized, covered entities will have a compliance period (likely 180 days to one year) to implement all requirements. However, given the scope of changes, practices should begin preparations now.

What Small Practices Should Do Now

1. Assess Your Current State

Conduct an honest evaluation of your current security posture. Do you have encryption? MFA? Documented policies? Understanding your gaps now gives you time to address them.

2. Budget for Compliance

The new requirements will cost money. Small practices may need to invest in new security tools, upgrade systems, and potentially engage IT support. Start budgeting now rather than scrambling later.

3. Implement MFA Immediately

MFA is coming regardless of the final rule. It's also one of the most effective security measures available. Implement it now for all systems accessing patient data.

4. Review Business Associate Relationships

Identify all vendors with access to your ePHI. Do you have current BAAs? Can they demonstrate their security controls? Start these conversations before the verification requirement takes effect.

5. Test Your Backup and Recovery

Can you actually restore your systems within 72 hours? Test it. Many practices discover their backups don't work when they need them most.

The Cost of Non-Compliance

HIPAA penalties range from $100 to $50,000 per violation, with annual maximums of $1.5 million per violation category. But the real cost of a breach goes far beyond fines:

• Patient notification and credit monitoring expenses
• Legal fees and potential lawsuits
• Reputation damage and patient loss
• Operational disruption during recovery
• Increased insurance premiums

Get Expert Help with HIPAA Compliance

The 2026 HIPAA Security Rule changes represent a significant shift in compliance expectations. Smith Network Solutions helps medical practices throughout Metro Atlanta prepare for and maintain HIPAA compliance with practical, cost-effective IT solutions.

Contact us today for a free HIPAA security assessment and learn where your practice stands before the new requirements take effect.