“Are you HIPAA certified”? If you’ve asked this question of your MSP or been asked this question by your customer, you likely know the frustration and confusion that can follow. The provider may note in response that they are HITRUST certified. And…more confusion as they attempt to explain the difference. Understanding the differences between HIPAA and HITRUST is crucial for organizations to ensure data security and maintain regulatory compliance. Let’s break down each framework and highlight their key distinctions. Then, we can review which best fits different organization types.
HIPAA: The Regulatory Floor
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) is a federal law establishing mandatory security and privacy standards for safeguarding Protected Health Information (PHI).
HIPAA consists of 3 major rules:
- Privacy Rule: Governs how covered entities (CEs) and business associates (BAs) can use and disclose PHI.
- Security Rule: Establishes standards for protecting electronic PHI (ePHI), outlining administrative, physical, and technical safeguards.
- Breach Notification Rule: Requires notification to individuals, the Department of Health and Human Services (HHS), and potentially the media in case of a PHI breach.
HIPAA is non-prescriptive, meaning it provides high-level standards rather than specific technical requirements. This flexibility allows organizations of various sizes to tailor their security measures. Compliance is generally self-assessed, although CEs often require BAs to demonstrate compliance through agreements or audits. The ultimate enforcement authority rests with the HHS Office for Civil Rights (OCR).
HITRUST: The Security Ceiling
The Health Information Trust Alliance (HITRUST) Common Security Framework (CSF) is a voluntary, comprehensive security framework. It pulls standards like HIPAA, ISO 27001, PCI, GDPR, NIST, and others together into one simple roadmap.
HITRUST provides granular control requirements and implementation specifications tailored to an organization’s specific risks and complexity (determined by risk factors and scope).
The defining feature of HITRUST is its validated certification program. Organizations undergo rigorous third-party assessment by an external assessor, culminating in a detailed report and, if successful, a certification valid for two years. This certification offers an industry-recognized validation of a strong security posture.
Key Differences at a Glance
| Feature | HIPAA | HITRUST CSF |
| Type | Mandatory Federal Law | Voluntary Security Framework |
| Focus | Primarily PHI Security & Privacy | Broad Information Security (including PHI) |
| Approach | Non-Prescriptive Standards | Highly Prescriptive Controls |
| Validation | Self-Assessment (often) | Rigorous Third-Party Assessment |
| Certification | No Official HIPAA Certification | HITRUST Validated Certification Available |
| Enforcement | OCR (HHS) | Market Driven / Business Partner Requirements |
Which Fits Best and Why?
HIPAA is the absolute minimum requirement for all covered entities and business associates. It’s fundamental.
HITRUST is best suited for:
- Large & Complex Organizations: Health systems, major insurers, and large-scale healthcare IT vendors benefit from the structure and prescriptive nature of the HITRUST CSF to manage complex security risks systematically.
- High-Risk Organizations: Entities processing vast amounts of highly sensitive ePHI find HITRUST’s rigorous controls essential for mitigating risk.
- Organizations Seeking Competitive Advantage: A HITRUST certification demonstrates a robust commitment to security, which can differentiate them in proposals and simplify vendor security assessments by third parties. Major health plans increasingly require HITRUST CSF certification from their business associates.
- Organizations with International Operations: HITRUST CSF integrates global standards (like ISO 27001), providing a unified framework manageable across regions.
For smaller, lower-risk organizations, the cost and effort of achieving HITRUST certification might outweigh the immediate benefits. However, implementing the HITRUST CSF as an internal framework to meet and exceed HIPAA standards can still be extremely valuable.
Ultimately, HIPAA defines what must be protected, while HITRUST offers a powerful, validated framework for how to achieve comprehensive and provable security.
References
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- U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR): “Health Information Privacy.” https://www.hhs.gov/hipaa/index.html
- HITRUST: “The HITRUST CSF.” https://hitrustalliance.net/hitrust-csf/
- U.S. Department of Health and Human Services (HHS), Office of the National Coordinator for Health Information Technology (ONC): “Guide to Privacy and Security of Electronic Health Information.” https://www.healthit.gov/topic/privacy-security-and-hipaa/guide-privacy-and-security-electronic-health-information
