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Small size does not exempt a medical practice from the HIPAA Security Rule. If your practice is a covered entity or business associate within the rule’s scope, it must protect electronic protected health information (ePHI) with appropriate administrative, physical, and technical safeguards. The practical starting point is a documented risk analysis—not a particular product, checklist, or consultant.
What HIPAA requires of a small practice
The Security Rule applies to covered entities and business associates within its scope. It protects ePHI that an organization creates, receives, uses, or maintains, and requires safeguards for its confidentiality, integrity, and availability. HHS describes the standard in its HIPAA Security Rule overview.
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HHS’s summary of the Security Rule identifies several core duties: conduct an accurate and thorough assessment of risks and vulnerabilities to ePHI; implement security measures that reduce risks to a reasonable and appropriate level; designate a security official; and establish workforce and information-access controls. The rule also calls for reviewing records to detect security incidents, periodically evaluating security measures, and regularly reevaluating risks.
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These are ongoing responsibilities, not a one-time setup exercise. The rule does not prescribe one identical control set for every practice: the risk analysis informs which measures are reasonable and appropriate for the organization’s circumstances.
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Start with a risk analysis that reflects how the practice works
Map where the practice creates, receives, maintains, and transmits ePHI. Include more than the electronic health record: consider the systems, devices, vendors, workflows, and access practices involved in handling the information. Assess potential risks and vulnerabilities, then use the findings to decide what safeguards and risk-management measures are needed.
Keep the analysis and decisions documented, and revisit them when systems, vendors, work practices, or risks change. A checklist can help organize the work, but completing one does not by itself establish compliance.
Use the HHS/ONC tool if it fits your practice
The downloadable HHS/ONC Security Risk Assessment Tool is an official starting point aimed at small and medium providers. The ONC page, last updated September 18, 2026, lists version 3.7 and cautions that the tool may not be appropriate for larger organizations. It is assistance, not a certification of compliance. HHS also notes that NIST standards referenced by the tool are informational; the Security Rule does not require those standards themselves.
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Professional assistance is another possible route when the practice needs help scoping systems, documenting findings, or following through on remediation. Whether using a tool or outside support, make sure the work reflects the practice’s actual environment and produces usable decisions—not merely a completed form.
Assign responsibility and make access reviewable
Designate a security official who is responsible for coordinating the work. Document how workforce members are authorized to access information, what access they receive, and how access is controlled. Review those processes and security measures periodically, and maintain procedures for detecting and responding to incidents.
Ownership matters in a small office where IT tasks may be shared or handled by outside providers. A vendor can perform work, but the practice still needs to know who is accountable for decisions, what information the vendor handles, and how risks are addressed.
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Check vendors that handle PHI
When a covered entity engages a business associate to help carry out healthcare activities or functions, HHS says the parties must have a written contract or other arrangement specifying the work and requiring protection of PHI. Business associates are directly liable for some HIPAA provisions. See HHS’s guidance on covered entities and business associates.
For a cloud service provider that handles ePHI, HHS says the customer must obtain satisfactory assurances through a business associate agreement. HHS does not expressly require the provider to supply security documentation or allow customer audits. A practice may seek additional assurances based on its risk analysis and compliance needs, but should not mistake any one contract term for a complete security review.
A disposal contractor may also be a business associate. Outsourcing destruction does not remove the need to safeguard PHI before and during pickup; the agreement should require the vendor to protect it.
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Dispose of paper and electronic PHI safely
HIPAA requires reasonable safeguards for PHI in any form, but HHS does not mandate one disposal method. The appropriate method depends on the practice’s circumstances and the form, type, and amount of information. HHS’s disposal guidance gives examples rather than prescribing a specific device or service.
Paper records
HHS lists shredding, burning, pulping, or pulverizing as possible methods, provided the information is rendered essentially unreadable, indecipherable, and unreconstructable. Records awaiting pickup can be kept in secure storage. Publicly accessible trash is generally not appropriate for PHI unless it has first been rendered essentially unreadable, indecipherable, and unreconstructable, according to HHS’s dumpster FAQ, content-reviewed August 12, 2026.
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Electronic media
The Security Rule requires policies and procedures for final disposition of ePHI and reuse of electronic media. HHS describes clearing, purging, or destroying media as possible approaches. Choose and document a method suited to the media and information involved rather than assuming paper-record procedures also address electronic devices.
In-house destruction or a disposal vendor
Either approach can be considered against the same practical questions: Is PHI protected while it awaits disposal? Does the process render it unreconstructable? Does it cover electronic media where relevant? If a vendor handles PHI as a business associate, is an appropriate agreement in place? The right choice depends on the practice’s circumstances.
Do not treat the proposed Security Rule as current law
HHS lists “HIPAA Security Rule to Strengthen the Cybersecurity of Electronic Protected Health Information,” published January 6, 2025, as a proposed rule on its Security Rule page. Proposed requirements should not be described as binding current requirements unless a later final rule has made them so. The existing Security Rule duties described above remain the baseline presented on that page.
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What enforcement illustrates—and what it does not
On April 25, 2025, HHS’s Office for Civil Rights announced a settlement with Comprehensive Neurology, a small New York neurology practice, following a ransomware investigation. OCR described it as its 12th ransomware enforcement action and the eighth enforcement action in its Risk Analysis Initiative at that time, emphasizing the Security Rule’s risk-analysis provision. This dated example shows enforcement attention to risk analysis; it does not establish that every small practice has the same risks or will face the same outcome. See the OCR announcement.
Account for rules beyond federal HIPAA
This federal overview does not resolve state-specific requirements. State medical-record retention and disposal rules may also apply, so practices should check the rules relevant to their location and records. HHS does not certify products or endorse private compliance systems; no software, device, contract, or outside service should be presented as automatic proof of HIPAA compliance.
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