Main takeaways from this article:
HIPAA compliance in the cloud is a shared responsibility between healthcare organizations and CSPs, requiring thorough risk analyses, access controls, and contractual assurances like business associate agreements (BAAs).
Key challenges to achieving HIPAA compliance include evolving regulatory requirements, misconfiguration risks, lack of data visibility, and third-party vendor dependencies, all of which require proactive management.
Best practices for HIPAA-compliant cloud computing include encrypting PHI, automating data classification, conducting regular risk assessments, monitoring cloud activity continuously, and developing a well-documented incident response plan.
Wiz simplifies HIPAA compliance by providing a unified cloud security platform with automated compliance assessments, visibility into risks, and actionable remediation recommendations, empowering healthcare organizations to maintain secure and compliant cloud environments.
HIPAA and cloud compliance refresher
HIPAA, enacted in 1996, is a crucial regulation for safeguarding sensitive patient data in the U.S. healthcare system. As healthcare organizations depend more on cloud services, HIPAA's Security Rule is more relevant than ever in protecting electronic protected health information (ePHI) against cloud threats.
The regulation applies to healthcare providers, insurers, and their business associates, including cloud service providers handling ePHI. As healthcare organizations adopt cloud solutions for their scalability and cost-effectiveness, they must ensure compliance through business associate agreements (BAAs) and implement robust cybersecurity measures.
Key aspects of HIPAA's cybersecurity requirements include:
Risk assessment and management
Implementation of administrative, technical, and physical safeguards
Encryption of ePHI
Regular security updates and patch management
Employee training on cybersecurity best practices
As cyber threats evolve, HIPAA-regulated entities must continually adapt their security strategies to protect patient data effectively.
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Key HIPAA rules
The two most important HIPAA Title II rules in relation to your compliance and security responsibilities are as follows.
HIPAA Privacy Rule
The Privacy Rule aims to strike a balance between the role of data in providing treatment and the protection of patient privacy.
It serves three main purposes.
It specifies the circumstances under which a covered entity may use or disclose an individual's PHI.
It gives patients the right of access to their PHI.
It permits the sharing of PHI with other HIPAA-covered entities to ensure all parties involved in a patient's treatment have access to the information they need to provide an optimum level of care.
HIPAA Security Rule
The Security Rule focuses on ensuring the confidentiality, integrity, and availability of PHI that's stored and processed electronically.
It takes a risk-based approach to data protection, taking into consideration the risks to PHI, the likely impact of any incident, and the resources a covered entity or BA has at its disposal.
The National Institute of Standards and Technology (NIST) has published a document explaining how to implement the rule in practice. Although voluntary, compliance with the guidelines will help ensure your physical, administrative, and technical safeguards are aligned with Security Rule provisions.
The U.S. Department of Health and Human Services Office for Civil Rights is responsible for enforcement of both Privacy and Security Rules and has the power to issue penalties for violations.
However, there is no official certification for HIPAA compliance. So when a third party states that it is HIPAA compliant, it simply means it provides you with all the controls and tooling to help you meet the regulation's requirements.
HIPAA cloud compliance: who holds the responsibility?
When an organization hosts PHI in the cloud, responsibility for safeguarding its security, integrity, and availability is shared between the covered entity or business associate and the cloud service provider (CSP). Both parties must work together to meet HIPAA compliance requirements.
Cloud providers
Implement technical safeguards: CSPs must provide secure infrastructure, including encryption for data in transit and at rest, access controls, and activity logging to detect unauthorized access.
Offer contractual assurances: CSPs are required to sign a business associate agreement (BAA) with the covered entity or BA, outlining their responsibilities for protecting PHI.
Maintain compliance documentation: CSPs must document their compliance measures and provide assurances that their systems meet HIPAA standards.
Support audits and assessments: CSPs should assist covered entities by offering audit logs, security reports, and certifications to facilitate compliance checks.
Healthcare organizations (covered entities and BAs)
Conduct a risk analysis: Perform a detailed assessment of PHI to identify vulnerabilities, risks, and the necessary controls to protect the data.
Enforce access controls: Limit PHI access to authorized personnel only, using multi-factor authentication (MFA) and role-based permissions.
Monitor PHI activities: Regularly review system logs and activity reports to identify potential risks or unauthorized access attempts.
Establish policies and training: Develop policies for secure PHI handling and train staff on HIPAA compliance best practices, including their role in maintaining security.
Verify vendor compliance: Ensure the CSP adheres to HIPAA standards and their BAA obligations by reviewing their security measures and certifications regularly.
By clearly defining and fulfilling their responsibilities, both parties can create a secure, compliant environment for managing PHI in the cloud.
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Challenges of ensuring a HIPAA-compliant cloud
Achieving and maintaining HIPAA compliance in the cloud presents unique challenges due to the complexity of healthcare data and the regulatory requirements that govern it. To tackle these challenges, organizations need a proactive security approach that makes the most of HIPAA-compliant cloud services.
Evolving regulatory landscape: HIPAA regulations are subject to updates and reinterpretations that can impact compliance requirements. Keeping pace with changes while managing other overlapping regulations, such as GDPR or PCI DSS, adds complexity for healthcare providers operating in the cloud. Organizations must continuously monitor for regulatory updates and adjust their security and compliance practices accordingly.
Misconfiguration risks: Cloud environments are highly customizable, but misconfigured resources—such as public-facing storage buckets or weak access controls—can expose PHI to unauthorized access. Even small errors can lead to significant breaches. Regular audits, automated configuration checks, and tools like Wiz can help identify and correct misconfigurations promptly.
Data visibility and classification: Healthcare providers often struggle to maintain clear visibility into where PHI resides and how it is accessed in the cloud. Without proper classification and monitoring, sensitive data can become scattered, increasing non-compliance risk. Solutions that automatically detect, classify, and monitor PHI ensure continuous visibility and protection.
Third-party vendor risks: Many healthcare organizations rely on third-party vendors for cloud services and integrations, creating a shared responsibility for compliance. However, not all vendors adhere to the same standards. This underscores the importance of thorough due diligence, contractual agreements, and ongoing vendor compliance monitoring.
Best practices for HIPAA-compliant cloud computing
Ensuring HIPAA compliance in the cloud demands a strategic approach that prioritizes data protection and aligns with regulatory standards. Adopting proven best practices can help healthcare organizations mitigate risks and maintain secure cloud environments.
1. Establish responsibilities with a business associate agreement (BAA)
Once both parties have clearly defined their roles and responsibilities for meeting Security Rule requirements, these details should be documented in the BAA.
Larger CSPs like AWS, Microsoft Azure, and Google Cloud Platform often provide standard BAAs. These agreements may be available upon request or included in the provider’s terms and conditions. If you use such a CSP:
Thoroughly review which services are covered by their BAA.
Disable any services that are not included to avoid compliance gaps.
In some cases, CSPs incorporate third-party solutions as part of their services. These solutions must also comply with HIPAA requirements, and this compliance should be explicitly documented in the BAA to ensure end-to-end coverage.
2. Ensure service-level agreements (SLAs) meet HIPAA needs
Before entering into a business relationship with a CSP, you should check that their SLA meets HIPAA expectations for service availability. It should promise near 100% uptime and meet your recovery time objective (RTO) and recovery point objective (RPO) to be sure of fast recovery and minimum loss of data in the event of unexpected downtime.
You should also check that the SLA is consistent with both your BAA and the HIPAA. For example, you should pay due consideration to terms relating to use, retention, and disclosure, security responsibilities, and how data will be returned to you on termination of service.
3. Encrypt patient data effectively
If a CSP hosts encrypted PHI on your behalf then it is still classed as a BA even if it doesn't have access to the encryption keys and is therefore unable to view the data. This is because it still has to meet HIPAA requirements for maintaining the integrity and availability of such data.
However, under such circumstances, its obligations will be limited, leaving you accountable for much more of the shared responsibilities between you.
And, finally, be aware that you must encrypt patient data, both at rest and in transit, using an encryption algorithm that meets NIST requirements.
4. Automate data classification for HIPAA-sensitive data
Wiz's data classifier rules page
Data classification will help you establish what information in your data inventory comes within the scope of the HIPAA and therefore requires an appropriate level of protection.
However, this is a time-consuming and complex manual process, which is prone to human error. A new generation of data discovery, mapping and classification tools, on the other hand, can automatically scan and analyze your data to ensure fast, efficient and accurate detection of sensitive patient information.
They can also do so across a wide range of different data repositories, in both structured and unstructured form, to ensure full coverage across both cloud-based and on-premises infrastructure.
5. Configure cloud storage for HIPAA compliance
Cloud storage solutions that support HIPAA compliance will offer a full range of features to help ensure the confidentiality, integrity, and availability of your data. They should include functionality such as:
object versioning
robust access controls
activity logging and monitoring
immutable backups and snapshots
However, whether it's storage or any other service you use in the cloud, configuration is key to HIPAA compliance success. Because security capabilities are pointless if you don't configure them correctly.
6. Conduct regular risk assessments
Regular risk assessments are essential for identifying vulnerabilities that could compromise PHI and ensuring compliance with HIPAA’s Security Rule.
These assessments help evaluate risks such as misconfigured cloud resources, insider threats, and external attacks, all of which can expose sensitive data.
Documenting the findings from each assessment provides a clear overview of potential weaknesses and compliance gaps.
Organizations should implement remediation plans to address these risks promptly and revisit their assessments periodically to account for changes in their cloud environment.
7. Monitor and log cloud activity continuously
Continuous monitoring of cloud activity is crucial for detecting unauthorized access or unusual behaviors that could compromise PHI and violate HIPAA requirements.
Centralized logging tools play a key role by collecting, analyzing, and alerting on suspicious activities across cloud environments, helping organizations maintain a secure and compliant infrastructure.
Automating log analysis further streamlines threat detection and ensures timely responses while simplifying compliance reporting through clear and actionable insights.
8. Develop an incident response plan
A documented incident response plan is vital for meeting HIPAA’s requirements and minimizing the impact of security breaches involving PHI. The plan should include key components such as breach notification protocols to comply with HIPAA's Breach Notification Rule, clear mitigation steps to contain and address incidents, and recovery strategies to restore operations quickly.
Regularly testing and updating the plan ensures that it remains effective and actionable during real-world incidents, providing confidence in your organization’s ability to respond to emerging threats.
Choosing the right HIPAA-compliant cloud service provider
Selecting the right CSP is critical for HIPAA compliance and protecting PHI in the cloud. A provider’s experience, security offerings, and commitment to compliance should align with your organization’s specific needs.
1. Assess the provider's HIPAA compliance experience
Choose a CSP with a proven track record of supporting healthcare organizations and meeting HIPAA requirements. Look for case studies, customer references, or certifications that highlight their ability to manage PHI securely and comply with regulatory standards. This due diligence ensures the provider is equipped to handle the complexities of healthcare data.
2. Evaluate the provider's security capabilities
Ensure the cloud storage provider offers advanced security features such as encryption for data at rest and in transit, real-time monitoring, and access controls. These capabilities are critical for protecting PHI from unauthorized access and ensuring compliance with HIPAA’s stringent security requirements. A provider with strong security measures reduces your organization’s risk and reinforces trust in cloud operations.
3. Confirm scalability and flexibility
Scalability is essential to accommodate growing volumes of PHI and the increasing operational demands of healthcare organizations. A CSP should provide flexible solutions that expand with your needs while seamlessly integrating with your existing systems. This ensures uninterrupted workflows and optimizes the use of cloud resources as your organization evolves.
4. Prioritize transparency and vendor accountability
Clear documentation and open communication about compliance responsibilities are essential when partnering with a CSP. Ensure the provider outlines their obligations in detail, including incident response procedures and measures to safeguard PHI. Additionally, verify their readiness to support audits and compliance reporting to maintain accountability and alignment with HIPAA requirements.
5. Examine support and training resources
24/7 support and access to HIPAA-specific expertise are invaluable for troubleshooting issues and maintaining compliance. Evaluate the provider’s training materials and onboarding programs to ensure your team can effectively leverage their tools and features. Comprehensive support resources streamline adoption and enhance your organization’s ability to manage PHI securely.
Solutions to support HIPAA compliance
Privacy, security, and compliance are highly interrelated disciplines. So it makes sense to address these responsibilities using a single centralized solution.
In other words, tooling that not only provides capabilities to protect your information assets, but also maps your security posture against the provisions of laws such as the HIPAA.
Healthcare security solutions should help you identify compliance violations across a comprehensive array of controls. They should support a risk-based approach to security, in line with the underlying principle of the HIPAA Security Rule. And they should automatically benchmark your cloud deployments against a wide range of other compliance frameworks—so you can meet the requirements of many other regulations and standards from a single point of control.
Enter Wiz.
Wiz is a unified cloud security platform that includes automated compliance assessments against industry standard regulations and benchmarks, including HIPAA. Wiz continuously assesses your compliance posture across frameworks, projects, and subscriptions, and provides you with a comprehensive report of your findings.
Wiz can help you achieve HIPAA compliance by:
Providing you with visibility into your cloud environment, including all of your assets, configurations, and activities.
Identifying and assessing risks to your HIPAA compliance, such as misconfigurations, vulnerabilities, and unauthorized access.
Recommending remediation steps to mitigate risks and improve your compliance posture.
Generating compliance reports that you can use to demonstrate your compliance to auditors and regulators.
I'm a doctor, I take care of people, I was trained in preventative medicine. Wiz is like preventative medicine for us.
Alex Steinleitner, President & CEO, Artisan
Simplify HIPAA compliance with Wiz
HIPAA compliance in the cloud isn’t a one-time effort but an ongoing commitment to protecting PHI in a dynamic environment. By integrating security and compliance into every aspect of your cloud operations, you not only meet regulatory requirements but also build trust and resilience. The right strategy ensures your cloud environment remains secure as your organization evolves.
Wiz simplifies HIPAA compliance by providing a unified cloud security solution that identifies misconfigurations, monitors risks, and ensures continuous protection of sensitive data. With automated tools for data classification, real-time monitoring, and compliance reporting, Wiz empowers healthcare organizations to meet regulatory requirements with ease.
Ready to enhance your compliance strategy? Get a demo and discover how Wiz can help secure your cloud environment while streamlining HIPAA compliance efforts.
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