Cybersecurity for healthcare practices with 2 to 50 staff
Short answer
A small practice protects patient data by doing a written risk analysis first, as 45 CFR 164.308(a)(1)(ii)(A) requires, and then fixing what it finds. For most practices the fixes start with MFA on email and remote access, one login per person, endpoint detection and response on every computer, an email provider under a business associate agreement, offline or immutable backups, and staff training. HHS's 405(d) program and its Cybersecurity Performance Goals list the same basics for small organizations.
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This page explains what the rules and the providers say. It isn't legal or compliance advice. Confirm your specific situation with a qualified professional.
On this page
- Who this page is for
- What this usually looks like
- What the HIPAA Security Rule requires
- Start with the risk analysis
- The federal playbooks for small organizations
- Ransomware and email threats: what the sources say
- Controls mapped to the services that deliver them
- Options compared
- What it costs
- A 90-day plan by practice size
- The proposed Security Rule update
- Common mistakes
Who this page is for
- You own or manage a medical, dental, therapy or chiropractic practice with 2 to 50 staff.
- Nobody on staff does IT full time.
- You know HIPAA has a Security Rule, but you aren’t sure what it asks for in practice.
- Your cyber insurance renewal, a payer contract or a scary news story is pushing you to act.
If you run a law firm, the duties are different. Start with cybersecurity for law firms instead.
What this usually looks like
A typical case: an eight-person family practice. Everyone shares two front desk logins. The EHR is in the cloud, but scanned referrals sit on a Windows PC in the back office. Email runs on a business plan nobody has looked at in years. Backups go to a USB drive that stays plugged in.
Then the cyber insurance renewal asks about MFA on all remote access and email, EDR on every endpoint, and the date of the last risk assessment. The office manager doesn’t know the answers.
That practice needs a written risk analysis, a short list of fixes in the right order, and services set up correctly.
What the HIPAA Security Rule requires
The Security Rule covers electronic protected health information (ePHI). It applies to covered entities, such as health care providers that conduct certain transactions electronically, and to their business associates. The rule’s general requirement, in 45 CFR 164.306, is to protect the confidentiality, integrity and availability of ePHI against reasonably anticipated threats.
The rule is flexible on purpose. Under 164.306(b), a practice can choose measures based on its size, complexity and capabilities, its technical infrastructure, the cost of the measures, and the probability and criticality of risks.
Each standard has implementation specifications marked “Required” or “Addressable.” Addressable doesn’t mean optional. Under 164.306(d), you must assess each one, implement it if it is reasonable and appropriate, or document why not and implement an equivalent alternative where reasonable.
| Safeguard type | Where it is | What it covers | Examples of required specifications |
|---|---|---|---|
| Administrative | 45 CFR 164.308 | Risk analysis, risk management, security official, workforce access, training, incident procedures, contingency plan, evaluation, business associate contracts | Risk analysis, risk management, sanction policy, activity review, incident response and reporting, data backup plan, disaster recovery plan, emergency mode operation plan |
| Physical | 45 CFR 164.310 | Facility access, workstation use and security, device and media controls | Disposal of ePHI and hardware, removing ePHI before media re-use |
| Technical | 45 CFR 164.312 | Access control, audit controls, integrity, authentication, transmission security | Unique user identification, emergency access procedure |
| Documentation | 45 CFR 164.316 | Written policies and records | Keep documentation 6 years, make it available, review and update it |
Encryption, automatic logoff, security reminders and log-in monitoring are all addressable. That is why two practices can make different choices, as long as each documents its reasoning.
Start with the risk analysis
The first required specification in the rule is the risk analysis: “an accurate and thorough assessment of the potential risks and vulnerabilities” to ePHI, under 164.308(a)(1)(ii)(A). The next one, risk management, requires measures that reduce those risks “to a reasonable and appropriate level.”
HHS’s Guidance on Risk Analysis says the rule doesn’t prescribe a method, and that the process “should be ongoing.” It also says the rule doesn’t set a frequency.
OCR enforces this. In 2025 and 2026, HHS press releases describe a Risk Analysis Initiative and a run of settlements where OCR found no accurate and thorough risk analysis. One was a small New York neurology practice that paid $25,000 after ransomware encrypted its network, according to the April 25, 2025 HHS release.
The HIPAA risk assessment guide explains what HHS expects in one, how to use the HHS SRA Tool, which HHS offers as a direct download, and when to bring in outside help.
The federal playbooks for small organizations
HICP 2023 and Technical Volume 1
HHS’s 405(d) program publishes the Health Industry Cybersecurity Practices (HICP). The 2023 edition names five top threats: social engineering, ransomware, loss or theft of equipment or data, insider data loss, and attacks against network connected medical devices.
It answers them with ten practices. Technical Volume 1 is written for small organizations without dedicated IT or security staff. Its sub-practices are short and concrete:
| HICP practice | Small-organization sub-practices | What it means in a small office |
|---|---|---|
| 1. Email protection | 1.S.A configuration, 1.S.B education, 1.S.C phishing simulations | MFA on email, filtering, external tags, encryption for PHI |
| 2. Endpoint protection | 2.S.A basic controls | Antivirus or EDR, disk encryption, automatic patching, no local admin rights, MFA for remote access |
| 3. Access management | 3.S.A basic access management | One account per person, MFA on admin and VPN, separate admin accounts, same-day removal |
| 4. Data protection | 4.S.A to 4.S.C | Policies, procedures and training on where PHI may go |
| 5. Asset management | 5.S.A to 5.S.C | Inventory, buying and retiring devices safely |
| 6. Network management | 6.S.A to 6.S.C | Separate guest Wi-Fi, locked network closet |
| 7. Vulnerability management | 7.S.A | Find and fix missing patches |
| 8. Incident response | 8.S.A, 8.S.B | A written plan and information sharing |
| 9. Medical devices | 9.S.A | Security for connected devices, like imaging |
| 10. Governance | 10.S.A to 10.S.D | Policies, risk assessment, training, cyber insurance |
HICP is voluntary, but it turns the Security Rule’s general standards into a to-do list sized for a small office.
The healthcare Cybersecurity Performance Goals
HHS also publishes voluntary healthcare Cybersecurity Performance Goals (CPGs). The ten essential goals are:
- Mitigate known vulnerabilities
- Email security
- Multifactor authentication
- Basic cybersecurity training
- Strong encryption
- Revoke credentials for departing workforce members
- Basic incident planning and preparedness
- Unique credentials
- Separate user and privileged accounts
- Vendor and supplier cybersecurity requirements
The enhanced goals add items like asset inventory, network segmentation and centralized log collection.
Ransomware and email threats: what the sources say
- HHS says reports of large breaches rose 102 percent from 2018 to 2023, on its NPRM page.
- The same HHS page says large breaches affected over 167 million people in 2023.
- In April 2026, OCR’s director said “Hacking and ransomware are the most frequent type of large breach reported to OCR,” in the four-settlement release.
- The FBI’s 2025 Internet Crime Report counts 24,768 business email compromise complaints with about $3.05 billion in reported losses in 2025.
- The same report says the top ransomware variants most affected critical manufacturing, healthcare and public health, and government facilities.
Ransomware also has a HIPAA consequence. HHS’s ransomware fact sheet says that when ransomware encrypts ePHI, a breach is presumed unless the practice shows a low probability that the PHI was compromised.
Controls mapped to the services that deliver them
Each row is a control, the rule or practice behind it, and the kind of service that provides it.
| Control | Rule or guidance | Service category | Providers I work with | Options I don’t work with |
|---|---|---|---|---|
| MFA on email, remote access and admin accounts | HICP 3.S.A; CPG MFA; 164.312(d) | Built into your email platform, plus a password manager | Keeper; Coro | Google Workspace, Microsoft 365, 1Password |
| Endpoint detection and response | HICP 2.S.A; 164.308(a)(5)(ii)(B) | EDR, or managed EDR or MDR with people watching alerts | Huntress; CyberMaxx; Coro | Microsoft Defender for Business |
| Email security and encryption | HICP 1.S.A; 164.312(e) | Email filtering and encrypted email under a BAA | Coro | Google Workspace, Microsoft 365, Paubox, Virtru, LuxSci |
| Backups you can restore | 164.308(a)(7)(ii)(A) | Backup with an offline or immutable copy | Coro lists a cloud backup module | Your IT company’s backup tool |
| Training and phishing tests | 164.308(a)(5); HICP 1.S.B, 1.S.C | Security awareness training | Hook Security; Coro; Huntress | KnowBe4 |
| Secure fax | Privacy Rule safeguards; 164.312(e); BAA | Cloud fax under a BAA | Documo; Cloudli | eFax Corporate, SRFax, iFax |
| Risk analysis | 164.308(a)(1)(ii)(A) | Assessment service or the HHS SRA Tool | CyberMaxx [VERIFICAR] | HHS SRA Tool (do it yourself) |
Details for email are on the HIPAA compliant email page. Fax options are on the HIPAA compliant online fax page. If you use Google, read Google Workspace and HIPAA before anything else.
Options compared
| Provider or option | Best for | How it works | Pricing info (as of October 2026) | Pros | Cons |
|---|---|---|---|---|---|
| Coro (I work with them) | Practices that want one dashboard for endpoint, email and cloud apps | Packages like Coro AI Essentials bundle endpoint security, EDR, email security and cloud app security; Coro says its data protection can scan files and email for PHI | Not published; quote through a partner or Coro (pricing page) | One agent and one console for a small team | BAA not confirmed on its public pages [VERIFICAR]; still needs someone to review alerts |
| Huntress (I work with them) | Practices that want managed EDR instead of a tool they watch themselves | Managed EDR, plus managed identity protection for Microsoft 365 and Google accounts, SIEM and security awareness training | Managed EDR MSRP $8.99 per endpoint per month; 50-seat minimum when bought direct or through a reseller (pricing) | Published prices; no Huntress-required seat minimum when bought through an MSP | The 50-seat direct minimum doesn’t fit a 10-person office, so a small practice would buy through an IT provider |
| CyberMaxx (I work with them) | Practices with 25 to 50 staff, or several locations, that want a full MDR service | MaxxMDR, described as 24x7x365 detection and response, with a healthcare page | Not published | Full detection and response service | Priced by quote; a 5-person office may not need this level of service |
| Hook Security (I work with them) | Short, regular staff training and phishing tests | 3 to 5 minute modules, a HIPAA compliance track and automated phishing simulations (details) | Per seat, not published | Short lessons that fit between patients | Training alone doesn’t stop attacks |
| Keeper (I work with them) | Replacing shared passwords and spreadsheets | Business password manager with shared folders and admin controls | Business Starter is for 5 to 10 users; prices didn’t display when I checked [VERIFICAR] | Keeper says its platform is HIPAA compliant (source) | BAA terms not confirmed [VERIFICAR] |
| Microsoft Defender for Business (I don’t work with them) | Practices on Microsoft 365 that want EDR at a low list price | Device security for up to 300 users; included in Microsoft 365 Business Premium | $3.00 per user per month, paid yearly (Microsoft) | Low cost; one vendor with your email | You or your IT company must watch the alerts |
| KnowBe4 (I don’t work with them) | Practices that want published per-seat prices for training | Training plus phishing simulations | From $2.40 per seat per month for 25 to 50 seats on a 3-year term, prices as of May 2026 (KnowBe4) | Published prices | 25-seat lowest band and 3-year term |
What it costs
I only quote published list prices. As of October 2026:
- Microsoft Defender for Business: $3.00 per user per month, paid yearly.
- Huntress Managed EDR: MSRP $8.99 per endpoint per month, with $7.99 shown as the example at 100 endpoints.
- KnowBe4 SAT Foundation: $2.40 per seat per month at 25 to 50 seats on a 3-year term.
- Documo cloud fax: from $25 per month on the annual Solo plan (Documo pricing).
Coro, CyberMaxx, Hook Security and Cloudli quote by request. What moves the price most is the number of users and devices, whether a person watches alerts 24/7, contract length, and whether your IT company already resells one of these tools.
If you want to see which gaps you actually have before you price anything, use the HIPAA security checklist.
A 90-day plan by practice size
These timelines assume no active incident. If you’ve had one, contact your cyber insurer’s hotline and your IT company first.
2 to 10 staff
- Days 1 to 30: confirm the BAA with your email provider, turn on MFA for every mailbox, give everyone their own login, and start the HHS SRA Tool.
- Days 31 to 60: put EDR on every computer, encrypt laptops, move passwords into a password manager, and set up a backup copy that isn’t on the office network.
- Days 61 to 90: finish the risk analysis and risk management plan, run a first phishing test, and write a one-page incident response plan.
11 to 25 staff
- Days 1 to 30: everything above, plus an inventory of every device, including imaging and lab equipment.
- Days 31 to 60: managed EDR or MDR so alerts don’t sit unread, separate admin accounts, and a list of every vendor that touches PHI with a BAA for each.
- Days 61 to 90: a test restore, monthly training, and a tabletop run of the incident plan.
26 to 50 staff or several locations
- Days 1 to 30: consider an outside risk assessment, since the scope is bigger.
- Days 31 to 60: MDR with 24/7 coverage, network segmentation between clinical devices and guest Wi-Fi, and centralized logging.
- Days 61 to 90: written security expectations for your IT provider, an annual training calendar, and a review of what your cyber insurer asked at the last renewal.
The cyber insurance requirements guide lines these steps up with renewal questions. Dental offices have extra items, like imaging PCs and shared front desk logins, covered on the dental office page.
The proposed Security Rule update
Status as of October 2026: proposed, not law. HHS published a notice of proposed rulemaking in the Federal Register on January 6, 2025, and comments closed March 7, 2025. The current federal regulatory agenda lists it (RIN 0945-AA22) as a long-term action with final action targeted for July 2027. HHS says the current Security Rule remains in effect while rulemaking continues.
The HHS fact sheet says the proposal would remove the required versus addressable distinction, require encryption of ePHI at rest and in transit and MFA (with limited exceptions), a technology asset inventory and network map, a compliance audit at least once every 12 months, vulnerability scanning at least every six months, penetration testing at least once every 12 months, and procedures to restore certain systems within 72 hours.
None of those proposals is a legal requirement today. Many of them already show up in HICP, in the CPGs and on insurance applications, so doing them now is rarely wasted.
Common mistakes
- Buying tools before the risk analysis. You end up paying for features you don’t need and missing the gap that matters, like a backup drive that’s always plugged in.
- Treating a vendor certificate as compliance. A “HIPAA compliant” badge or a signed BAA covers the vendor’s side. Your configuration, policies and training are still yours.
- Shared logins at the front desk. The rule requires unique user identification under 164.312(a)(2)(i). Shared accounts also make any investigation guesswork.
- EDR with nobody watching. An alert that sits in an inbox at 2 am doesn’t stop ransomware. Decide who responds, or pay for managed EDR or MDR.
- Backups on the same network. Ransomware that encrypts your server can reach a mapped backup drive. Keep one copy offline or immutable, and test a restore.
- Ignoring the IT company’s own access. Your outside IT provider likely needs a BAA, and MFA on its remote tools.
Definitions for terms like ePHI, MDR and immutable backup are in the glossary.
If you want me to line up these services for your practice and compare at least two options for each gap, send me your practice details through the quote form.
Frequently asked questions
What are the HIPAA Security Rule requirements for a small practice?
The Security Rule requires administrative, physical and technical safeguards for electronic PHI, plus written policies kept for 6 years. It starts with a required risk analysis and risk management under 45 CFR 164.308(a)(1). The rule lets a practice scale its measures to its size, budget and risks under 45 CFR 164.306(b).
Does a small medical practice need EDR?
The Security Rule doesn't name EDR. It does include protection from malicious software as an addressable specification, plus any safeguard your risk analysis shows you need. HICP lists endpoint protection for every device, and CISA's ransomware guide recommends EDR on all assets.
What is HICP?
HICP is the Health Industry Cybersecurity Practices publication from HHS's 405(d) program. The 2023 edition names five top threats and ten practices, and Technical Volume 1 is written for small organizations. It is voluntary guidance, not a regulation.
Are the HHS Cybersecurity Performance Goals mandatory?
No. HHS describes the healthcare CPGs as voluntary. They are a short list of essential and enhanced practices, such as MFA, email security and basic incident planning, meant to help organizations set priorities.
Was the new HIPAA Security Rule finalized?
Not as of October 2026. HHS published a proposed rule on January 6, 2025, and the current federal regulatory agenda lists it as a long-term action with final action targeted for July 2027. The current Security Rule stays in effect.
Can a product make my practice HIPAA compliant?
No. A product can carry a BAA and provide safeguards, but compliance depends on your risk analysis, policies, configuration and training. Microsoft says this directly: using its services doesn't on its own achieve HIPAA compliance.
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Sources
- eCFR: 45 CFR 164.306, Security standards: General rules · accessed October 2026
- eCFR: 45 CFR 164.308, Administrative safeguards · accessed October 2026
- eCFR: 45 CFR 164.310, Physical safeguards · accessed October 2026
- eCFR: 45 CFR 164.312, Technical safeguards · accessed October 2026
- eCFR: 45 CFR 164.316, Policies and procedures and documentation requirements · accessed October 2026
- HHS: Guidance on Risk Analysis · accessed October 2026
- HHS Cyber Gateway: Health Industry Cybersecurity Practices (HICP) · accessed October 2026
- HHS 405(d): HICP Technical Volume 1, Cybersecurity Practices for Small Health Care Organizations (2023) · accessed October 2026
- HHS Cyber Gateway: Healthcare and Public Health Cybersecurity Performance Goals · accessed October 2026
- HHS: HIPAA Security Rule NPRM · accessed October 2026
- HHS: HIPAA Security Rule NPRM fact sheet · accessed October 2026
- Federal Register: HIPAA Security Rule To Strengthen the Cybersecurity of Electronic Protected Health Information (proposed rule, January 6, 2025) · accessed October 2026
- Reginfo.gov: Unified Agenda entry for RIN 0945-AA22 · accessed October 2026
- HHS press release: OCR settles four HIPAA Security Rule ransomware investigations (April 23, 2026) · accessed October 2026
- HHS press release: OCR settles ransomware investigation with neurology practice (April 25, 2025) · accessed October 2026
- HHS OCR: Ransomware and HIPAA fact sheet (2016) · accessed October 2026
- FBI IC3: 2025 Internet Crime Report · accessed October 2026
- CISA: #StopRansomware Guide · accessed October 2026
- Microsoft Learn: HIPAA and HITECH Act offering · accessed October 2026
- Microsoft: Defender for Business · accessed October 2026
- Huntress: Pricing · accessed October 2026
- Coro: Pricing · accessed October 2026
- Coro: Healthcare · accessed October 2026
- Coro: Platform overview · accessed October 2026
- CyberMaxx: Healthcare MDR · accessed October 2026
- Hook Security: Security awareness training · accessed October 2026
- KnowBe4: Pricing · accessed October 2026
- Keeper Security: Business password manager · accessed October 2026
- Documo: Cloud fax pricing · accessed October 2026