09/29/2026
The HIPAA security risk analysis is still the gap OCR keeps finding. (Link to the full recap article provided below) Takeaways an attorney-attendee reports from the OCR/NIST HIPAA Security Conference (Sept 2026):
🔹 Security Rule overhaul: OCR now projects its next formal action for July 2027. The final scope may change, but the direction won't.
🔹 "Addressable" ≠ optional. It has always meant you achieve the protection, implement the regulation, or document why not and implement an equivalent alternative.
🔹 What's actually new: asset inventory and network map, MFA, segmentation, regular vulnerability scans and pe*******on tests, 72-hour restoration plans, and annual business associate security compliance verification. The projected first-year cost is about $9B, and it likely hits small practices hardest.
🔹 The real problem today: a risk analysis has been required since 2005, and it's still missing or deficient in nearly every OCR investigation. A gap analysis doesn't count.
🔹 The standard: track ePHI as it enters, moves within, and leaves your organization, not just what's in the EHR.
✅ One action: If your risk analysis isn't thorough and done in the last 12-18 months, start there. Don't wait for the new rule! Apgar & Associates can help - now scheduling into Spring 2027!
(Article 🔗 of full recap from Jake Dewberry, JD: https://1l.ink/4NN7VC8)