How to Protect Patient Data Across Remote and Multi-Site Care

Protecting patient data across remote and multi-site care starts with a documented, recurring risk-management process—not a single app, device, or vendor. Under the HIPAA Security Rule, covered entities and business associates must use reasonable and appropriate safeguards to protect electronic protected health information (ePHI), wherever it is accessed, transmitted, or maintained.

What HIPAA requires when care is distributed

The HIPAA Security Rule establishes national standards for ePHI created, received, used, or maintained by covered entities and business associates. Covered entities include health plans, health care clearinghouses, and qualifying health care providers. The rule requires safeguards that protect ePHI’s confidentiality, integrity, and availability; guard against reasonably anticipated threats and impermissible uses or disclosures; and support workforce compliance.

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HHS describes the rule as technology neutral and scalable. It does not prescribe one universal security product or configuration. Instead, an organization must select reasonable and appropriate measures in light of its size and capabilities, technical infrastructure, costs, and the probability and criticality of risks. HHS explains the rule’s requirements in its Summary of the HIPAA Security Rule and provides related Security Rule guidance material.

Dispersed care changes where ePHI is handled and which people, devices, systems, vendors, and locations may expose it. That makes remote access, mobile devices, telehealth communications, and vendor services part of the organization’s risk analysis—not exceptions to its obligations.

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Build the program around a recurring risk-management cycle

Use the organization’s actual care workflows to decide what needs protection and whether safeguards are working. HHS’s guidance covers risk analysis, remote use and access, mobile devices, and ransomware; the right control set depends on the organization’s documented risks.

1. Map ePHI and its paths. Identify what ePHI the organization creates, receives, uses, or maintains, and where it is stored or transmitted. Include the people, work locations, devices, applications, networks, and vendors involved in handling it.
2. Assess threats and vulnerabilities. Consider how remote connections, mobile devices, telehealth conversations, software weaknesses, accidental disclosure, and vendor systems could affect confidentiality, integrity, or availability. Evaluate both the likelihood and the potential impact of those risks.
3. Select safeguards that fit the risks. Decide how access should be authorized, authenticated, limited to job needs, and recorded. Consider how devices and sessions are protected, how changes are handled, and what safeguards are needed for the organization’s technical infrastructure and workforce practices.
4. Assign responsibility and prepare the workforce. Make clear who approves access, who reviews it, who handles devices and vendor changes, and who responds to suspected incidents. Workforce policies and practices should support compliance with the safeguards.
5. Check and update the program. Review whether access remains appropriate and whether controls and policies still address the organization’s risks. Track incidents, evaluate safeguards periodically, and reassess when care workflows, technology, vendors, or locations change.

For example, if a staff member loses a device, the response should follow the organization’s established incident process, not depend on an informal assumption about what data was on it. A vendor changing how its service works is likewise a reason to revisit the relevant risks and responsibilities.

Make remote access and mobile use fit the workflow

Remote work can extend ePHI access beyond a clinic or hospital’s usual physical boundaries. Start by establishing who needs access and why, then review whether authorization matches each person’s role. HHS identifies role-appropriate authorization, access review, incident tracking, and periodic evaluation as elements of the Security Rule’s risk-management approach.

Include the devices and systems that staff use to reach or handle ePHI in the risk analysis. A policy that covers only organization-owned equipment may miss relevant workflows if staff use mobile devices or access services from other locations. HHS’s Security Rule guidance includes resources on remote access and mobile devices, as well as risk analysis and ransomware. Those resources support risk-based decisions; they are not a universal checklist that establishes compliance on its own.

Address telehealth privacy and technology separately

Telehealth creates both organizational security concerns and practical privacy concerns in the room where a visit takes place. HHS’s guidance for patients recommends choosing a private location. If that is not possible, headphones, turning the screen away from other people, and avoiding speakerphone can reduce the chance that others hear or see the conversation. These steps address a specific patient privacy situation; they do not secure ePHI stored or transmitted by a device or replace an organization’s safeguards.

For providers, HHS identifies risks that include malware, unpatched software, and accidental disclosure, and advises explaining vendors’ privacy and security practices to patients. When assessing a telehealth service, consider the vendor’s relevant privacy practices, agreed safeguards, and use of online tracking technologies, along with how the organization will communicate applicable practices to patients. HHS offers guidance for health care providers educating patients about remote communication technologies and telehealth privacy and security tips for patients.

Do not treat a vendor agreement or security product as the whole program

A vendor relationship belongs in the organization’s risk-management process because the service may create, receive, maintain, or transmit ePHI. Assess the risks and safeguards relevant to that service, define responsibility, and revisit the assessment if the service or workflow changes. A business associate agreement, a vendor’s security claims, or a purchased product alone does not demonstrate that the organization has addressed its risks or met its obligations.

HHS’s technology-neutral approach also means there is no single configuration that works for every organization. When choosing safeguards or services, weigh risk coverage, workforce and access needs, compatibility with existing infrastructure, implementation and operating costs, and the ability to evaluate them over time. A control that is technically available but does not fit actual workflows may leave important access or handling paths unaddressed.

Understand the proposed Security Rule update

HHS says the Office for Civil Rights issued a proposed update to the HIPAA Security Rule on December 27, 2024. HHS’s NPRM page states that the current Security Rule remains in effect while rulemaking proceeds; the proposal should not be described as a final rule. See the HIPAA Security Rule NPRM page for the agency’s status information.

In its 2024 announcement, OCR reported that from 2018 through 2023, reports of large breaches increased by 102 percent and the number of individuals affected by large breaches increased by 1,002 percent. OCR also reported that more than 167 million individuals were affected by large breaches in 2023. The announcement said large breaches caused by hacking and ransomware increased by 89 percent and 102 percent, respectively, since 2019. These are HHS-reported figures and describe large breaches; they do not measure remote-work risk at a particular organization.

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