HIPAA security awareness training is essential for healthcare organizations and their employees.  The HIPAA Security Rule requires covered entities (CEs) to have a security awareness training program in place that helps ensure their workforce understands how to protect the privacy and security of patient information.  This blog post will discuss the basics of HIPAA security awareness training, what it should cover, and the frequency with which employees should take the training.  By understanding these key components, you can ensure that your organization remains HIPAA compliant and that your employees are informed of the importance of protecting patient data.

What is HIPAA Security Awareness Training?

HIPAA security awareness training is a mandatory training program that aims to educate employees about the importance of maintaining patient confidentiality, safeguarding sensitive data, and complying with HIPAA.  The purpose of the training is to help employees understand their responsibilities when handling sensitive information and to prevent breaches, security incidents, and other HIPAA violations.

HIPAA security awareness training is an integral part of HIPAA compliance and applies to all CEs and business associates (BAs) that handle protected health information (PHI).  The training is designed to ensure that employees understand the rules, regulations, and procedures related to PHI, as well as their roles and responsibilities in protecting patient privacy.

What Should the Training Cover?

Training typically covers a range of topics related to data security, privacy, and compliance.  This includes the basics of HIPAA regulations, the importance of PHI security, the types of PHI, the handling and disclosure of PHI, risk assessments, and incident reporting.  It may also include topics such as password management, network security, physical security, and device management.

HIPAA explicitly calls out required training in two sections: 45 CFR §164.530(b) (the Privacy Rule) and 45 CFR §164.308(a)(5) (the Security Rule – Administrative Safeguards).  However, as with most of the requirements in HIPAA & HITECH, the requirements are pretty vague, with §164.530 simply stating that individuals be trained “on the policies and procedures with respect to [PHI]… as necessary & appropriate for the members of the workforce to carry out their functions within the [CE].”

§164.308 states that a “security awareness and training program” must be implemented.  Four items are listed in the implementation specifications: security reminders (periodic security updates), protection from malware, login monitoring, and password management.

When developing and implementing a security awareness training program, it is important that an organization keep in mind the “spirit of the law” as opposed to the “letter of the law.”  If an organization were to only train its employees on the four items from §164.308, there would be significant gaps in the subject matter that would expose the organization to potential data breaches.

Basic HIPAA Security Awareness Training

For most of a CEs workforce, basic HIPAA awareness training will suffice.  The following topics should be covered in basic HIPAA training:

1. Overview of HIPAA: Provide an understanding of the purpose and requirements of the HIPAA Privacy Rule and what it mandates.  It should also cover the Security Rule, including the importance of protecting electronic protected health information (ePHI).
2. Privacy and Security Policies: Review the organization’s policies and procedures related to privacy and security, emphasizing the need for confidentiality and the proper handling of ePHI.
3. Protected Health Information (PHI): Educate employees about the types of information considered PHI and the importance of safeguarding it from unauthorized access, use, or disclosure.
4. Security Measures: Discuss the various security measures in place, such as access controls, encryption, firewalls, and antivirus software, and explain how these measures contribute to protecting ePHI.
5. Password and User Authentication: Train employees on the importance of creating strong passwords, regularly updating them, and the proper use of user authentication mechanisms to prevent unauthorized access.
6. Physical Security: Address the physical security measures in place, such as access control systems, surveillance cameras, and visitor management protocols, to protect physical areas where ePHI is stored or accessed.
7. Incident Reporting: Instruct employees on how to identify and report potential security incidents, such as suspected data breaches or unauthorized access to ePHI, emphasizing the importance of timely reporting.
8. Social Engineering and Phishing: Raise awareness about social engineering techniques and phishing attempts, providing examples and best practices to help employees recognize and respond to such threats.
9. Mobile Device Security: Educate employees about the proper use and protection of mobile devices (e.g., smartphones, tablets) that may have access to ePHI, including password protection, encryption, and remote wipe capabilities.
10. Consequences of Non-Compliance: Communicate the potential consequences of non-compliance with HIPAA regulations, including legal penalties, fines, disciplinary actions, and reputational damage to both individuals and the organization.

Overall, HIPAA security awareness training should help employees develop a strong understanding of the importance of protecting PHI and how to do so effectively.

Advanced HIPAA Security Awareness Training

While basic HIPAA training covers everything that most employees need to know about the privacy and security of PHI, there are certain roles within an organization that should go beyond the scope of this training.  Roles such as the Privacy Officer, Security Officer, and Health Information Management Systems (HIMS) roles require more advanced training to perform their job functions properly.  The following topics should be covered in an advanced HIPAA training course.

1. Emerging Threats and Evolving Risks: Discuss new and emerging threats in the healthcare industry, such as ransomware attacks, insider threats, and social engineering techniques.  Highlight the importance of staying updated on current security trends and adapting security practices accordingly.
2. Incident Response and Breach Management: Provide in-depth training on incident response protocols, including steps to identify, contain, mitigate, and report security incidents or breaches.  Emphasize the importance of timely and effective responses to minimize the impact on patient data and organizational reputation.
3. Security Audits and Assessments: Educate employees on the purpose and process of security audits and assessments, including internal and external evaluations.  Discuss the role of employees in supporting and participating in these audits, such as providing requested information and following audit recommendations.
4. Security Controls and Technologies: Explore advanced security controls and technologies relevant to HIPAA compliance, such as intrusion detection and prevention systems, data loss prevention solutions, encryption techniques, and secure coding practices.  Explain how these technologies contribute to protecting ePHI and maintaining a secure environment.
5. Privacy and Security Incident Examples: Present real-world examples of privacy and security incidents that have occurred in the healthcare industry.  Analyze the impact of these incidents, lessons learned, and preventive measures that could have been implemented.  This helps employees understand the potential consequences of non-compliance and reinforces the importance of vigilance in safeguarding patient data.
6. Role-Specific Training: Tailor the training content to address the unique security responsibilities and challenges specific to different job roles within the organization.  Provide targeted guidance and best practices based on employees’ roles, such as clinicians, IT administrators, or compliance personnel.
7. Third-Party Risk Management: Highlight the risks associated with working with third-party vendors, contractors, and business associates who have access to ePHI.  Train employees on how to evaluate and manage these risks effectively, including the importance of due diligence, proper contract agreements, and ongoing monitoring of third-party compliance.
8. Regulatory Updates and Changes: Keep employees informed about any recent updates, changes, or proposed revisions to HIPAA regulations and related privacy and security laws.  Discuss the potential impact of these changes on daily practices and emphasize the importance of remaining compliant with the evolving regulatory landscape.

How Often Should Employees Take the Training?

HIPAA security awareness training is an ongoing process that helps employees stay informed about the latest developments in the healthcare industry.  To ensure compliance with HIPAA regulations, employees should take this training on a regular basis.

The frequency with which employees should take training will depend on a variety of factors, including the size of the organization, the nature of the work performed by employees, and the level of risk associated with the organization’s operations.

In general, it is recommended that employees take HIPAA security awareness training at least once a year.  This annual training should cover any updates or changes to the HIPAA regulations, as well as any new threats or vulnerabilities that have emerged in the past year.

In addition to the annual training, employees should also receive refresher training whenever there is a significant change in the organization’s operations or policies, such as the implementation of a new electronic health record (EHR) system or the adoption of new security measures.  Training should also be conducted whenever there are material changes to federal or state regulations that would affect how the organization handles PHI.

It is important to note that HIPAA security awareness training is not a one-time event but rather an ongoing process that requires regular attention and updating.  By keeping employees informed and educated about HIPAA regulations and best practices, organizations can help prevent breaches and protect the privacy and security of their patient’s sensitive information.

If your organization needs assistance in creating and implementing a HIPAA security awareness training program, Axeleos can help! Contact us today to discuss how we can assist your organization.