Follow a recommended frequency for HIPAA risk analysis: Expert

by: DecisionHealth Staff Jun 8, 2025

In the May 19 issue of Part B News, a recent enforcement action by the HHS Office for Civil Rights (OCR) highlighted the consequences of failing to conduct an adequate risk analysis under the HIPAA Security Rule (link here, subscription required). Find out what one compliance expert recommends for conducting risk analysis within your practice.

The HIPAA Security Rule does not mandate a specific frequency for risk analyses, but best practices suggest conducting them at least annually or whenever a major change occurs.

“The frequency of revisiting a risk analysis, in my opinion, is a case-by-case decision based on various factors specific to a HIPAA-regulated entity,” says Frank Ruelas, MBA, a compliance professional. “For example, if a covered entity is in a growth phase, it may be continuously adopting new technology as it develops its service lines.”

Situations that warrant an updated risk analysis include the following:

New technologies or EHR system upgrades. Assess security risks before and after implementation.
Policy changes or regulatory updates. Ensure compliance with evolving HIPAA security requirements.
Security incidents or breaches. “Often reviewing the apparent or contributing causes and root causes to the breach can also signal that there are threats or vulnerabilities that were not considered in previous risk analysis,” Ruelas says.
Annual reviews. Even without major changes, organizations should proactively revisit analysis to ensure no gaps emerge over time.

Risk analysis is not just about regulatory compliance; it is essential for protecting patient data, ensuring operational efficiency, and minimizing security risks.

You can take an active role by:

Using reliable risk analysis tools to identify and address vulnerabilities.
Embedding security awareness into daily workflows to prevent data breaches.
Regularly revisiting risk analysis to keep pace with new threats and technological changes.

If organizations take a proactive approach, they can prevent risks before they turn into breaches, Ruelas says.

Blog Tags: compliance

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