Cybersecurity Awareness Month: Key Cybersecurity Controls and Practical Challenges

By the EHR Association’s Privacy & Security Workgroup

Health care faces several security risks that make a focus on cybersecurity particularly critical. In particular, the industry is challenged by dual threats: highly valuable patient data (worth more on the black market than financial data at this point) and system interdependencies that directly introduce additional risk. A single cyber incident can disrupt hospital operations, delay treatments, and even jeopardize patient safety. 

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EHRA Statement on 2025 Cybersecurity Awareness Month

October is Cybersecurity Awareness Month. The 2025 theme is “Building a Cyber Strong America,” highlighting the need to strengthen the country’s infrastructure against cyber threats and ensure resilience and security. In recognition of healthcare’s rising threat profile and the urgent need to shore up cybersecurity industry-wide, the EHR Association shares the following statement:

Cybersecurity Awareness Month is an ideal opportunity to highlight the healthcare industry’s unique security risks, in particular the dual threat we collectively face from the highly valuable patient data held in our health IT systems, as well as the critical dependencies that directly impact patient care. Health data is a top target for nefarious actors, and a single cyber incident can cause lasting harm by disrupting operations, delaying treatments, and jeopardizing lives. To reduce the industry’s risk profile, the EHR Association advocates for stronger protections and realistic, risk-based implementations of security safeguards that enhance resilience without overwhelming resource-constrained hospitals, health systems, and other provider organizations.

– EHR Association Privacy & Security Workgroup

HIPAA Security Rule Part Three: Risk-Based and Industry-Aligned Approaches Recommended

By the EHR Association Privacy & Security Workgroup

This three-part blog series shares the EHR Association’s stance on OCR’s proposed changes to the HIPAA Security Rule. Part one focused on our overarching concerns and issues with proposed definitions. Part two and this installment highlight our concerns with OCR’s proposed expectations. 

The HIPAA Security Rule is overdue for modernization, given the rapid pace of technological change and increasing cybersecurity threats. While we support OCR’s intent to strengthen protections for electronic protected health information (ePHI), our analysis of the HIPAA Security Rule to Strengthen the Cybersecurity of Electronic Protected Health Information raised concerns and questions we hope will be addressed before finalization.

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HIPAA Security Rule Part Two: Proposed Changes Require Clarity, Flexibility

By the EHR Association Privacy & Security Workgroup

This three-part blog series shares the EHR Association’s stance on OCR’s proposed changes to the HIPAA Security Rule. Part one focused on our overarching concerns and issues with proposed definitions. Part two focuses on several of the proposed standards.

Our analysis of proposed changes to the existing HIPAA Security Rule, released as HIPAA Security Rule to Strengthen the Cybersecurity of Electronic Protected Health Information, revealed a mixed bag of positive changes and areas of concern. In the first installment of this blog series, we noted the EHR Association’s appreciation for its enhancements to the cybersecurity baseline. However, we expressed concern about the resources and costs required for regulated entities to comply with the overhauled mandates. We also reviewed the feedback we shared with OCR on its proposed changes to key definitions.

In this installment, we highlight our concerns with several of OCR’s proposed expectations, drawing attention to the need for greater clarity and offering recommendations to ease compliance burdens while achieving intended outcomes. 

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HIPAA Security Rule Part One: Proposed Overhaul Closes Some Gaps, Opens Others

By the EHR Association Privacy & Security Workgroup

This three-part blog series shares the EHR Association’s stance on OCR’s proposed changes to the HIPAA Security Rule to Strengthen the Cybersecurity of Electronic Protected Health Information. Part one is focused on our overarching concerns and issues with proposed definitions.

Proposed changes to the existing HIPAA Security Rule, released as HIPAA Security Rule to Strengthen the Cybersecurity of Electronic Protected Health Information, include some long-overdue updates. However, the resources and costs required by healthcare provider organizations, health IT developers, and other regulated entities to comply with the sweeping changes will be too great for many to bear.

That was one of several important messages we shared with the HHS Office of Civil Rights (OCR) in our comment letter on the proposed rule

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CISA Proposes Practical Guidelines For Reporting Cyber Incidents

EHR Association Privacy & Security Workgroup

The Cybersecurity and Infrastructure Security Agency (CISA), responsible for coordinating cybersecurity programs within the U.S. and improving the government’s cybersecurity protections, proposed new reporting requirements under the Cyber Incident Reporting for Critical Infrastructure Act, or CIRCIA. The proposed rule lays out what incidents must be reported, by whom, and what the reports must contain. While the EHR Association provided comments of support for most areas, suggestions for potential refinement were also offered. 

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