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Make vendor risk part of the hospital’s risk-management program
Third-party risk is not limited to companies that store electronic protected health information (ePHI). A supplier may connect to hospital systems, provide cloud hosting or support, or deliver a service whose outage could disrupt operations or care. The right controls depend on what the vendor does and how the hospital uses it.
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NIST’s SP 800-161 Rev. 1 Update 1, published November 1, 2024 and updated January 6, 2025, recommends integrating cybersecurity supply-chain risk management into organizational risk activities. It covers strategy, policy, planning, and assessment of products and services. For hospitals, that means vendor decisions should connect to the institution’s broader security and operational risk decisions rather than live in a stand-alone questionnaire process.
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Start with an inventory that shows how each supplier relates to the hospital’s technology and operations. Include vendors with ePHI access and suppliers whose service or failure could affect system availability, patient care, or business continuity.
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- Service and owner: Record what the vendor provides and which hospital business or clinical owner is accountable for the relationship.
- Data: Identify whether the vendor creates, receives, maintains, or transmits ePHI or other sensitive information, and understand the relevant data flows.
- Access and connections: Document system integrations, remote access, privileged accounts, and other paths into hospital environments.
- Operational dependency: Note which workflows depend on the service and what disruption could mean for hospital operations or care delivery.
This is a practical way to apply NIST’s supply-chain scope and HHS’s organization-specific risk-analysis approach; it is not a verbatim HIPAA inventory checklist.
Prioritize assessments by exposure and impact
Hospitals should not treat every vendor as equally risky. Prioritize assessment effort using the vendor’s access, the sensitivity of the data involved, and the consequences of a compromise or outage. Relevant factors include ePHI handling, privileged or remote access, connectivity to hospital systems, service criticality, and the likely operational impact of disruption.
NIST SP 800-161 calls for risk assessment of products and services and a multilevel approach to supply-chain risk. HHS likewise says risk analysis must reflect the organization and its environment. These sources support a context-based method, not a universal scoring formula. HIPAA does not set one vendor risk score or a fixed reassessment interval.
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Assess safeguards and define what the hospital needs to know
Use a documented process to understand how a vendor protects the data and systems involved in its service. Assessment areas can include security governance, vulnerability handling, incident communication, and the information the hospital will need to manage its own risk. The appropriate depth depends on the vendor’s exposure and importance; no single questionnaire or certification establishes that a relationship is safe.
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The ONC/OCR Security Risk Assessment Tool can help organize threat and vulnerability assessment, asset management, and vendor-management work. Its page notes that NIST standards shown in the tool are informational; they are not themselves required for HIPAA risk analysis or risk-management compliance.
For broader program structure, NIST SP 800-66 Rev. 2, whose final publication was announced February 14, 2024, helps regulated entities implement the HIPAA Security Rule and plan activities for assessing and managing ePHI risk. It complements, rather than replaces, the hospital’s own analysis.
Use BAAs appropriately—and keep the hospital’s responsibility
When a cloud provider creates, receives, maintains, or transmits ePHI on behalf of a covered entity or business associate, HHS says the parties need an appropriate HIPAA-compliant BAA. The agreement establishes permitted and required uses and disclosures and requires appropriate safeguards, including applicable Security Rule requirements. See HHS guidance on HIPAA and cloud computing.
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Revisit risk when the relationship changes
Vendor risk evolves as services, data flows, access paths, ownership, and threat conditions change. Treat assessment as ongoing: revisit relevant findings when a material change occurs and document how those findings affect the hospital’s risk decisions. This lifecycle approach aligns with NIST’s supply-chain guidance and HHS risk-management principles.
HHS’s risk-analysis guidance describes risk analysis as foundational to choosing safeguards and emphasizes that it must account for each organization’s characteristics and environment. The Security Rule does not specify a universal frequency for risk analysis, so hospitals should not present a particular vendor reassessment schedule as a fixed HIPAA requirement.
Plan for security events and service disruption
For vendors that are important to care delivery or hospital operations, make sure the relationship supports timely coordination when a security event or outage occurs. As an operational practice, hospitals can define how the vendor will communicate relevant events, who will coordinate response, and what information is needed to assess impact. Tailor these expectations to the service and the hospital’s incident and continuity plans; the sources do not provide a universal contract-clause template.
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HHS’s Healthcare Sector Cybersecurity Performance Goals offer voluntary priorities for high-impact practices. They are guidance, not a replacement for applicable HIPAA duties. In 2024–2025, OCR said its audit program would review selected HIPAA Security Rule provisions most relevant to hacking and ransomware across 50 covered entities and business associates. That number describes the audit sample, not the prevalence of breaches or the effectiveness of any vendor control.
How the official resources fit together
| Resource | Purpose | Status and use |
|---|---|---|
| NIST SP 800-161 Rev. 1 Update 1 | Cross-sector cybersecurity supply-chain risk management for systems and organizations. | Guidance for integrating supply-chain risk into organizational risk management and assessing products and services. |
| NIST SP 800-66 Rev. 2 | Support for implementing the HIPAA Security Rule and managing ePHI risk. | Cybersecurity resource guide; it supports planning and implementation rather than substituting for the hospital’s analysis. |
| ONC/OCR Security Risk Assessment Tool | Assessment aid for threat, vulnerability, asset, and vendor-management work. | Tool to support workflows; NIST references in the tool are informational, not independent HIPAA requirements. |
| HHS Healthcare Sector Cybersecurity Performance Goals | Healthcare-specific prioritization of cybersecurity practices. | Voluntary guidance; applicable HIPAA Rules establish the relevant legal duties. |
For an overview of the risk-analysis principle behind these activities, see HHS OCR’s risk-analysis guidance. Hospitals should use these resources to inform a risk-based program, not as a substitute for decisions grounded in their own systems, vendors, and operational needs.
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