HIPAA 2026 Compliance Checklist for Healthcare Providers

January 29, 2026

Use this checklist to quickly assess your organization's readiness for the upcoming HIPAA Security Rule update.

1. Core Technical Safeguards

✅ MultiFactor Authentication (MFA) enabled on all systems

✅ Regular vulnerability scans performed

✅ Annual penetration test completed

✅ Audit logging enabled across all PHIrelated systems

✅ Audit logs reviewed using a documented schedule

2. Annual Testing & Documentation

✅ Annual HIPAA Security Risk Analysis completed

✅ Updated system inventory included in documentation

✅ Updated data flow diagrams created

✅ Annual incident response drill conducted

✅ Annual backup and disaster recovery testing performed

✅ All security policies reviewed and updated

3. Business Associate (BA) Oversight

✅ Updated list of all Business Associates maintained

✅ Signed and current BAA for every BA

✅ Annual BA compliance review conducted

✅ Documentation of vendor assessments retained

✅ Verification that each BA complies with updated HIPAA requirements

4. Administrative Safeguards

✅ Annual HIPAA security training completed by all staff

✅ Unique login credentials for all users

✅ Formal onboarding and offboarding process maintained

✅ Access privileges reviewed annually

✅ Policies for handling PHI updated and enforced

5. Physical Safeguards

✅ Secure workstation policies implemented

✅ Physical access to servers and networking equipment restricted

✅ Visitor access logged and monitored

✅ Mobile devices encrypted and able to be remotely wiped

✅ Facility security controls reviewed annually

6. Operational Readiness

✅ Annual cybersecurity budget approved

✅ IT/MSP aligned with HIPAA rule updates

✅ Clear ownership of compliance responsibilities assigned

✅ Gaps identified through assessments have remediation plans

✅ Continuous monitoring practices established