The proposed HIPAA Security Rule update has not been finalized yet, but small healthcare practices should not wait until the deadline is set to start preparing.
One practical step your organization can take now is to begin building, reviewing, or updating your asset inventory.
An asset inventory is a documented list of the systems, devices, software, vendors, and access points that may create, receive, maintain, or transmit electronic protected health information, also known as ePHI. While asset inventories have not historically been listed as a specific HIPAA Security Rule requirement, the proposed updates could make them a much more formal expectation.
More importantly, an asset inventory is a smart foundation for your overall security and compliance program.
Why does it matter?
Because you cannot protect what you do not know exists. If your practice does not have a clear picture of where ePHI lives, how it moves, and who can access it, your risk analysis may miss important gaps. That can make it harder to identify vulnerabilities, update policies, manage vendor risk, and show that your organization is taking reasonable steps to protect patient data.
A strong asset inventory should include:
- Hardware, such as computers, laptops, mobile devices, servers, medical devices, and equipment that touches ePHI
- Software and applications, including EHR/EMR systems, billing platforms, cloud tools, and other SaaS applications
- Data flows that show where ePHI is stored, transmitted, and accessed
- Vendors and business associates that interact with your systems or patient data
- Network components, such as routers, firewalls, remote access tools, and other connection points
- User access, including who has access to what and at what permission level
The goal is not perfection on day one. The goal is visibility.
Starting now gives your practice time to identify what you use, where patient data may be exposed, and which areas may need stronger safeguards. It can also make future compliance work easier if the proposed rule is finalized and organizations have a shorter window to act.
HIPAA Secure Now is here to help healthcare organizations take practical steps before the clock starts. For more information, or to request a sample Asset Inventory, please reach out to our compliance team.
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