HIPAA Enforcements in 2025: How Prepared is Your Organization?
Most healthcare compliance leaders expected senior leadership to prioritize data security after the Change Healthcare attacks. Yet our annual benchmark survey suggests this trend might not be so straightforward – putting many at risk in 2025.
The number of respondents that state their C-suite and board are supportive of compliance has actually decreased since 2023. And with fast-evolving regulations and increased OCR enforcement, those that cannot galvanize sufficient support may fall foul to expensive fines and reputational harm.
The following article breaks down a few key trends that compliance leaders can use to drive more urgency around compliance – and take more decisive action this year.
Three Ways Healthcare Compliance Programs Must Adapt
Our recent survey revealed a few clear factors that should be addressed to be prepared for growing HIPAA privacy enforcement:
1. Most Companies Are Not Prepared for Audits
The Office of Civil Rights (OCR) announced its intention to resume HIPAA audits at the end of 2025, but our data suggests many organizations may not be ready. Just 39% of respondents said they were “very prepared” for HIPAA or OCR audits; this is higher than previous years, but given the prospect of actual audits – it should be seen as a serious concern.
Our experts point to documentation as a key factor to consider here. Audits often come down to provability; can you actually show evidence of your key HIPAA indictors – such as training, policies and procedures, and risk assessments? These could be seen as protection; they can be used to prove that a breach or error is a “one off” rather than a symptom of negligence or compliance failures.
2. More Independent Privacy Reviews Are Needed
Just 29% of companies report having their HIPAA privacy program independently evaluated within the last year – and 43% say they have never had it independently assessed. While such evaluations are not mandatory, they are considered best practice and can be vital to eliminate blind spots your internal compliance teams miss.
It is particularly important to undertake such an assessment if you either have a small compliance team or are undergoing a transition. For example, introducing a new EHR or expanding into a new state can create novel Privacy requirements – and an independent assessor will be well placed to ensure you have successfully adjusted your program to account for them.
3. Slow Action on the OCR’s Final Rule
The OCR’s Reproductive Health Care Privacy Final Rule, finalized in 2024, includes changes that impact the Notice of Privacy Practices (NPP) requirements. These changes are set to take effect in 2026, required covered entities to update their NPP and related policies. It is best practice to get ahead of these changes, giving you time to make the necessary documentation and cultural changes to implement the adjustments. But 60% of organizations say they are waiting until closer to the official date to make changes and review their requirements.
There is some justification here; the change in administration may leave some uncertain how much will be altered in the coming months. But it fundamentally suggests that many organizations are still taking a “passive” approach to HIPAA compliance – and therefore putting themselves at unnecessary risk.
Take Control of Compliance with Strategic Management Services
At Strategic Management Services, we equip healthcare organizations with everything they need to take a more active approach to compliance – and protect their patients and reputations. From Privacy Program audits to remediation support, we offer everything you need to take control of HIPAA compliance and be prepared for enforcement.
Want to get ahead of compliance changes?
