Critical milestones and deadlines for achieving full compliance
New required specifications are now in force
Deprecated encryption methods must be disabled
Final deadline to disable TLS 1.1
All critical systems should have MFA enabled
All encryption upgrades must be complete
Enhanced risk analysis should be completed
Expected increase in compliance audits
The accelerated timeline for breach notification to HHS (previously 60 days)
For breaches affecting 500 or more individuals, covered entities must now notify HHS within 72 hours of discovery (down from 60 days). This requires rapid incident response capabilities and prepared notification procedures.
Smaller breaches (under 500 individuals) continue to be reported annually, but documentation must begin immediately upon discovery.
Immediate
Day 1
Day 2
Day 3
Days 1-60
The 72-hour timeline leaves minimal room for deliberation. Organizations must have: incident response plans tested and ready, breach notification templates prepared, executive escalation procedures established, and forensic capabilities available 24/7.
More comprehensive and frequent risk assessments with detailed documentation
Comprehensive catalog of all systems containing ePHI
Analysis of potential security threats and vulnerabilities
Systematic identification of security weaknesses
Assessment of potential harm from security incidents
Calculation of risk levels based on likelihood and impact
Implementation of safeguards to reduce identified risks
Annual comprehensive risk analysis
Full security risk assessment at least yearly
Ongoing risk monitoring
Continuous vulnerability scanning and threat assessment
Triggered assessments
Additional analysis when environment changes or incidents occur
Detailed methodology
Document approach, tools, and standards used
Risk calculations
Show how likelihood and impact were determined
Mitigation tracking
Document all controls and their effectiveness
Organize your compliance efforts by priority and category