Preparing for a HIPAA audit
Preparing for a HIPAA audit is simplified with TrustCloud! Learn more about TrustCloud’s HIPAA! If you’ve been through an audit in the past, you are well aware of how tedious and time-consuming the process can be for you and your team.
The people
When pursuing HIPAA compliance, you may want to consider appointing a compliance and/or security officer to lead the effort. This can be done by a compliance and/or security officer or by the team.
The compliance officer is responsible for developing any required procedures, conducting a risk assessment in coordination with senior management, investigating any incidents resulting in a breach, and reporting when a breach occurs.
The security officer is responsible for developing security policies, conducting training, creating a disaster recovery plan, testing systems, and implementing mechanisms to prevent unauthorized access to PHI.
The process
The HIPAA audit process is broken down into three major components:
Step 1: Understanding HIPAA security rule
TrustCloud supports and helps guide you in the process of being compliant with the Security Rule of HIPAA. The security rule is mandatory for all covered entities and business associates. Refer to the HIPAA Overview document to refresh your knowledge of the different parts of HIPAA.
It is important for you to spend time understanding the HIPAA Security Rule and knowing what constitutes a breach of ePHI and how to report a breach to the OCR if it occurs. The HIPAA Security Rule contains three required standards for implementation.
The Security Rule requires the implementation of three types of safeguards: 1) administrative, 2) physical, and 3) technical.
- Administrative safeguards
The Security Rule administrative safeguard provisions require Covered Entities (CE) and Business Associates (BA) to perform a risk analysis before considering any specific administrative, physical, or technical safeguards under the HIPAA Security Rule. The risk analysis should be an ongoing process. - Physical safeguards
The physical safeguards protect the physical security of your offices, where ePHI is stored or maintained. The safeguards include controls related to facility access and workstation security. - Technical safeguards
The Technical safeguards include measures, including firewalls, encryption, and data backup, to implement to keep ePHI secure. The safeguards include controls related to access controls, audit controls, integrity controls, and transmission security controls.
Step 2: Prepare materials
In this step, you will create a list of controls and policies to adopt, gather required evidence artifacts, document all necessary procedures, and provide adequate training to your team. TrustOps helps you automate much of this process and automatically maps your controls to the Code of Federal Regulations to make it easy for you to assess your systems, policies, and procedures. If you’re not a TrustOps user yet, contact the TrustCloud team.
Step 3: Complete the internal review
Whether or not you choose to do an independent assessment, you must first conduct a thorough internal review to ensure that you are meeting all requirements. The internal audit review analyzes your gaps against the HIPAA audit guidelines and can be used as your self-assessment.
Common HIPAA audit pitfalls (and how to dodge them)
HIPAA audits conducted by OCR focus intensely on three core areas; Administrative, Physical, and Technical Safeguards, with 87% of findings tied to inadequate risk assessments and access controls, according to recent enforcement trends. A surprising statistic: over 60% of organizations fail initial audits due to missing encryption for PHI in transit or at rest, despite it being a straightforward fix via tools like TLS 1.3 and AES-256 standards.
Auditors also scrutinize “business associate agreements” (BAAs) with vendors, where incomplete contracts lead to immediate citations, yet many overlook annual reviews of third-party access logs.
The real game-changer? Conducting mock audits quarterly using OCR’s official protocol, which reveals hidden gaps like unmonitored audit trails or untrained staff handling PHI. Proactively mapping data flows across your entire ecosystem, from EHR systems to cloud backups, uncovers blind spots before regulators do, while tabletop breach simulations build muscle memory for the 60-day notification rule. Organizations treating audits as “business as usual” rather than fire drills achieve certification 3x faster, transforming compliance from burden to competitive advantage.
The HIPAA audit
The HIPAA audit process involves a thorough review of an organization’s policies, procedures, and security measures to ensure compliance with HIPAA’s privacy and security rules. Auditors examine documentation, assess risk management practices, and evaluate safeguards for protecting patient information. Regular audits help identify gaps and enforce corrective actions to maintain compliance.
An organization can self-attest to HIPAA or choose a third-party independent assessor to perform HIPAA audits once every year. The outcome of the annual review of your HIPAA controls and program is a HIPAA attestation report, not a certification.
HIPAA audits can also occur as a result of random selection by the Office of Civil Rights (OCR).
