HIPAA Risk Analysis — The OCR's First Question in Every Audit
Lacking a current risk analysis is the single most common HIPAA violation. NIST 800-30 is the methodology OCR expects.
HIPAA Security Rule requires covered entities and business associates to perform a written risk analysis assessing potential threats to ePHI. OCR's first question in any audit: show me the risk analysis.
Step-by-step
- 1
Inventory ePHI
Where it lives — EHR, billing, email, mobile, backups.
- 2
Identify threats
Internal (workforce error, insider) and external (ransomware, phishing).
- 3
Assess vulnerabilities
Unpatched systems, weak access controls, missing BAAs.
- 4
Determine likelihood and impact
Rate each threat-vulnerability pair.
- 5
Document and remediate
Track findings and fix on a documented timeline.
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