Issue #1: HIPAA Enforcement Trends – What 2025 Is Teaching Us

2025 has become a defining year in HIPAA enforcement. From six-figure penalties levied against small practices to public breach settlements, OCR’s message is clear: compliance is not optional—and outdated policies are no longer defensible.

SecureHealth is tracking these patterns to help clinics like yours stay not just compliant, but resilient.

Enforcement Snapshot (Q3)

• $22.4M in fines issued so far

• 80% of recent OCR actions targeted small to mid-sized clinics

• Top violations:

  • Incomplete or outdated risk analyses

  • Weak access controls and offboarding

  • Missing or untested breach response plans

What We’re Seeing (and Why It Matters)

1. Outdated or Superficial Risk Analyses

• OCR continues to cite violations of 45 CFR §164.308(a)(1)(ii)(A) when entities fail to conduct a thorough and accurate risk analysis. Many clinics either use outdated templates or skip documentation altogether. This is one of the most cited deficiencies in 2025. 

2. Weak Access Controls & Poor Offboarding

• Under §164.308(a)(3)(ii)(B), covered entities must implement procedures for workforce access management. Yet enforcement reveals lingering access rights for terminated staff and insufficient role-based restrictions—direct HIPAA violations. 

3. Breach Response Plans Still Missing or Untested

• OCR expects documented and tested incident response procedures per §164.308(a)(6)(ii). Lack of these plans can lead to both compliance penalties and extended patient harm—especially in ransomware and misdirected email scenarios. 

✅ What Clinics Can Do Right Now 

1. Refresh Your Risk Analysis: Ensure it’s updated, documented, and tied to your current environment. 
2. Review User Access Monthly: Terminate inactive or unnecessary accounts immediately. 
3. Develop & Test Your Breach Response Plan: Include a call tree, containment steps, and PHI impact assessment. 

🛡️ How SecureHealth Risk Advisors Can Help 

- HIPAA-Aligned Security Risk Analysis (SRA) – Built on NIST SP 800-30, tailored to your environment 
- Access Control Playbook – Templates and guidance for least privilege, revocation, and audit trails 
- Incident Response SOP Kit – Customized workflows and readiness training 

📬 Final Thought 

Enforcement in 2025 is no longer just about large hospitals or blatant negligence—OCR is now focused on routine failures in small practices. If you're still relying on old policies or haven’t tested your breach response plan, the time to act is now.