HIPAA Security Rule Updates: What Dental Practices Need to Know

Published
February 4, 2025
 · By Reuben Kamp, CEO & Founder
HIPAA Security Rule Updates for Dentists | Darkhorse Tech
Compliance Watch

HIPAA Security Rule Updates: What Dental Practices Need to Know

OCR has proposed the first update to the HIPAA Security Rule in over a decade. Here's what the changes mean for your dental practice, and how to start preparing now.

5 MIN READHIPAA COMPLIANCESECURITY RULE
TL;DR

On December 27, 2024, OCR issued a Notice of Proposed Rulemaking to update the HIPAA Security Rule, published officially on January 6, 2025. "Addressable" safeguards would become required. Key changes include mandatory encryption of ePHI in transit and at rest, vulnerability scans every six months, annual penetration testing, formal patch management, MFA, network segmentation, annual compliance audits, and new business associate obligations. Dental practices should start preparing now.

As the CEO of Darkhorse Tech, I want to bring to your attention some significant proposed changes to the HIPAA Security Rule that could have a direct impact on your dental practice.

On December 27, 2024, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) issued a Notice of Proposed Rulemaking (NPRM) to update the Security Rule for the first time in over a decade. The official version was published on January 6, 2025. These updates are designed to improve clarity, enhance cybersecurity measures, and ensure better compliance in protecting electronic protected health information (ePHI). Let's break down what this means for dental practices.

Jan 6, 2025
NPRM published
The first update to the HIPAA Security Rule in over a decade

01A shift towards specific, mandatory security measures

Direct answerUnder the proposed rule, security measures previously labeled "addressable" would no longer be optional. All security standards would be required.

For years, the HIPAA Security Rule has been broad and flexible to accommodate various healthcare providers. However, OCR is now making it clear that certain cybersecurity measures are no longer optional. In the past, some security measures were labeled as "addressable," which led to confusion and noncompliance. Now, all security standards will be required, ensuring that dental practices take cybersecurity seriously.

02Focus on emerging technologies: AI, quantum computing, and more

OCR has highlighted artificial intelligence (AI), quantum computing, and virtual/augmented reality as emerging technologies that could impact data privacy. Even if your dental practice does not currently use these technologies, OCR wants you to evaluate their potential risks and implement security measures proactively.

03Written documentation and compliance audits

Written documentation has always been required under HIPAA, but OCR has found that many organizations fail to maintain up-to-date policies. The proposed rule emphasizes the necessity of regularly evaluating and updating all security policies and procedures. Additionally, dental practices will be required to conduct annual compliance audits to assess their adherence to security standards. These audits will serve as critical documentation if your practice ever faces an OCR investigation.

04Stricter data protection standards

Direct answerePHI must be encrypted both in transit and at rest, practices must run vulnerability scans at least every six months and penetration tests at least once a year, and formal patch management policies are required.

Some of the most impactful changes include:

Mandatory encryption

ePHI must now be encrypted both in transit and at rest, ensuring that patient data remains protected from cyber threats.

Vulnerability scanning and penetration testing

Vulnerability scans at least every six months and penetration testing at least once a year, to identify security gaps before cybercriminals exploit them.

Patch management requirements

Formal patch management policies to ensure timely updates of software and systems, reducing vulnerabilities.

05Strengthened access control and authentication

Cybersecurity threats are often tied to unauthorized access. The new rule will require:

  • Multi-factor authentication (MFA): Dental practices must implement MFA to verify user identities before accessing ePHI.
  • Network segmentation: Practices must restrict access to sensitive data, ensuring that only authorized personnel have access.

06Business associate contracts and responsibilities

Direct answerBusiness associates that handle ePHI, such as IT providers, billing services, or cloud storage companies, must verify at least annually that they've implemented the required security controls, and notify covered entities within 24 hours of activating their contingency plans due to security incidents.

If you work with third-party vendors handling ePHI (such as IT providers, billing services, or cloud storage companies), the proposed rule places new requirements on them as well. Business associates must now:

  • Verify, at least annually, that they have implemented the required security controls.
  • Notify covered entities within 24 hours of activating their contingency plans due to security incidents.

07New compliance deadlines and expectations

To ensure timely compliance, the OCR is introducing specific deadlines for security reviews:

  • Policies and procedures must be reviewed, updated, and verified at least once every 12 months.
  • Certain security measures (such as vulnerability scanning and penetration testing) must be performed at regular intervals.
RequirementFrequency
Vulnerability scanningAt least every six months
Penetration testingAt least once a year
Compliance auditAnnually
Review, update, and verify policies and proceduresAt least once every 12 months
Business associate verification of security controlsAt least annually
Business associate notice after activating contingency plansWithin 24 hours

08What this means for your dental practice

Direct answerAssess your current security measures against the new requirements, implement encryption and MFA, regularly test your defenses with vulnerability scanning and penetration testing, update written policies and perform annual compliance audits, and make sure your business associates comply.

These updates signal a shift in how the government views cybersecurity in healthcare, and the changes are particularly relevant to dental practices, which often have smaller IT teams and fewer cybersecurity resources. However, compliance is no longer just about avoiding fines — it's about protecting your patients' data and maintaining trust.

Actionable steps for dental practices

  1. 1
    Assess your current security measuresMeasure them against the new requirements.
  2. 2
    Implement encryption and multi-factor authenticationSafeguard ePHI.
  3. 3
    Regularly test your cybersecurity defensesUse vulnerability scanning and penetration testing.
  4. 4
    Update written policies and perform annual compliance audits
  5. 5
    Ensure business associates complyWith the updated HIPAA Security Rule.

At Darkhorse Tech, we specialize in helping dental practices stay ahead of these regulatory changes while maintaining seamless, secure IT operations. If you have questions about how these HIPAA updates will impact your practice or need assistance in meeting compliance requirements, we are here to help. The proposed rule is currently open for public comment until March 7, 2025, so there is still time for adjustments before finalization. However, given the direction OCR is taking, dental practices should start preparing now.

Need help staying compliant?

Darkhorse Tech is committed to ensuring that dental professionals have the most up-to-date cybersecurity solutions to meet HIPAA requirements. Contact us today to learn how we can help safeguard your practice against evolving threats.

RK
Reuben Kamp
CEO & Founder, Darkhorse Tech

Frequently asked questions

What changed in the proposed HIPAA Security Rule update?
On December 27, 2024, OCR issued a Notice of Proposed Rulemaking to update the Security Rule for the first time in over a decade, with the official version published on January 6, 2025. Security measures previously labeled "addressable" would no longer be optional; all security standards would be required.
Does the proposed HIPAA rule require encryption?
Yes. Under the proposed rule, ePHI must be encrypted both in transit and at rest.
How often will dental practices need vulnerability scans and penetration tests?
The proposed rule requires vulnerability scans at least every six months and penetration testing at least once a year.
What new requirements apply to business associates?
Business associates handling ePHI, such as IT providers, billing services, or cloud storage companies, must verify at least annually that they have implemented the required security controls, and notify covered entities within 24 hours of activating their contingency plans due to security incidents.
What should dental practices do to prepare?
Assess current security measures against the new requirements, implement encryption and multi-factor authentication, regularly test defenses through vulnerability scanning and penetration testing, update written policies and perform annual compliance audits, and ensure business associates comply.

Darkhorse Tech is here for you.

Your dental technology should support your practice, not slow it down. Darkhorse Tech helps dental offices stay secure, connected, and productive with IT support built specifically for dentistry.

Schedule a Consultation Today

Back to Education

Looking to get dental IT support for the first time?

You’re in the right place.

Don’t hesitate to drop us a line, we look forward to connecting with you soon.

Thank you! Your submission has been received!
Oops! Something went wrong while submitting the form.

Want To Chat?

You can schedule an intro meeting online! Find a time on our calendar that works for you.

schedule today!