HIPAA SRA 2026: What’s New

Healthcare organizations have never faced more pressure to prove compliance—not just claim it. As we move into 2026, the HIPAA Security Risk Assessment (SRA) continues to be the foundation of compliance, enforcement, and cybersecurity readiness. But expectations around how SRAs are performed, documented, and acted upon have changed. For small and midsize healthcare practices, this is a critical shift. Regulators are paying closer attention to documentation gaps, unmanaged vendors, and incomplete remediation plans—areas that often fall outside the scope of day-to-day IT work. That’s why many healthcare practices are turning to managed IT services providers in San Diego with healthcare expertise to help keep pace. In this article we break down what’s new with HIPAA SRAs in 2026, what hasn’t changed (but still causes trouble), and how practices can prepare without overwhelming internal staff.

Why HIPAA SRAs Matter More Than Ever in 2026

HIPAA requires covered entities and business associates to conduct a thorough and accurate risk analysis of potential risks to electronic protected health information (ePHI). While this requirement has existed for years, enforcement trends show that the Office for Civil Rights (OCR) is increasingly focused on how SRAs are conducted—not just whether a checkbox exists. Key drivers behind the heightened scrutiny include:

• Rising cyberattacks on smaller practices. Attackers know smaller healthcare organizations often lack dedicated security teams, yet still hold highly valuable patient data.
• Expanded use of cloud platforms and telehealth. Remote access, cloud electronic health records (EHRs), and third-party applications increase the attack surface and the complexity of risk analysis.
• Post-breach investigations. Many OCR enforcement actions begin after a ransomware or phishing incident reveals gaps in risk assessment and remediation.

An SRA is no longer just a compliance document. It’s a roadmap regulators expect you to follow.

What’s New with HIPAA SRAs in 2026

1. Stronger Emphasis on Continuous Risk Management

In 2026, OCR guidance and enforcement trends continue to reinforce that an SRA is not a one-time event. Annual assessments remain the minimum expectation, but updates are increasingly required for scenarios such as:

• New systems or vendors are introduced: Adding new software, devices, or service providers can create fresh exposure points that must be evaluated before ePHI is placed at risk.
• Cloud migrations occur: Moving data or applications to the cloud changes how information is stored, accessed, and secured, requiring an updated risk analysis.
• Telehealth or remote access expands: Each new remote access pathway increases the attack surface and must be assessed to ensure secure authentication and data transmission.
• A security incident or near-miss is detected: Even unsuccessful attacks can reveal weaknesses that should trigger a reassessment and corrective action.

Practices that perform an SRA once and never revisit it are now at higher risk of non-compliance findings.

2. Documentation Is as Important as the Assessment Itself

One of the most common issues cited in enforcement actions isn’t the absence of security controls, but the lack of clear documentation. OCR increasingly expects practices to document:

• Identified risks: Practices must clearly record where vulnerabilities exist so there is a defensible record of awareness and oversight.

• Likelihood and potential impact: Documenting how likely a risk is and the damage it could cause shows regulators that risks are evaluated in a structured, reasoned way.

• Mitigation steps taken: OCR expects evidence that identified risks led to concrete security improvements, not just theoretical recommendations.

• Timelines for remediation: Assigning deadlines demonstrates accountability and prevents known issues from lingering unresolved.

In 2026, OCR expects SRAs to tie directly into written policies, technical safeguards, and operational decisions. This is where many practices struggle without structured IT governance.

3. Third-Party and Vendor Risk Is Under the Microscope

Business associates remain a major source of HIPAA exposure. SRAs must now more explicitly account for:

• Cloud service providers: Practices must understand how cloud vendors store, encrypt, and safeguard ePHI beyond simply trusting their compliance claims.

• IT vendors and MSPs: Managed service providers often have deep system access, making their security controls a critical part of overall HIPAA compliance.

• EHR platforms: Since EHRs are central repositories for patient data, their security posture directly impacts risk exposure.

• Billing, transcription, and telehealth vendors: These vendors frequently handle ePHI outside the primary network, increasing the importance of vetting and ongoing oversight.

Simply having a Business Associate Agreement (BAA) on file is no longer enough. Practices are expected to demonstrate due diligence in how vendors protect ePHI and integrate with internal systems.

4. Ransomware Preparedness Is Expected, Not Optional

Ransomware continues to be treated as a presumed breach unless proven otherwise. As a result, SRAs in 2026 are expected to address:

• Backup integrity and testing: Backups must be regularly tested to ensure they can be restored quickly and are not themselves compromised.
• Incident response workflows: A documented response plan helps staff act decisively during an attack rather than improvising under pressure.
• Detection and response capabilities: Early detection tools reduce downtime and limit the spread of ransomware across systems.
• Access controls and privilege management: Restricting user permissions helps prevent attackers from moving laterally and escalating damage after an initial breach.

Failing to assess ransomware readiness is increasingly viewed as a material compliance gap.

Common HIPAA SRA Gaps Still Causing Trouble

Even with clearer guidance, many healthcare organizations repeat the same mistakes, such as:

• Generic or templated SRAs that don’t reflect the actual environment: Boilerplate assessments often fail to account for the actual systems, workflows, and risks specific to a practice.
• No linkage between identified risks and remediation actions: Identifying risks without documenting how they were addressed leaves organizations vulnerable during audits and investigations.
• Incomplete asset inventories (especially cloud apps and endpoints): Untracked devices and applications can expose ePHI without being included in security controls or monitoring.
• Over-reliance on internal staff without compliance expertise: Internal teams may manage day-to-day IT effectively but lack the regulatory perspective required for defensible HIPAA documentation.

These gaps often surface only after an incident, when OCR requests documentation and finds inconsistencies.

How Managed IT Services Help Close the Gap

For many practices, the most practical way to meet 2026 expectations is through healthcare-focused managed IT services. A qualified MSP can:

• Conduct and document HIPAA-aligned SRAs: Managed IT providers ensure assessments meet regulatory expectations while maintaining clear, audit-ready documentation.
• Map technical controls directly to identified risks: This alignment demonstrates that security tools are deployed intentionally to address specific compliance gaps.
• Manage encryption, access controls, and endpoint security: Centralized oversight helps ensure ePHI is protected consistently across all systems and devices.
• Oversee vendor risk and BAA tracking: Managed services help maintain visibility into third-party compliance obligations and documentation.
• Support incident response planning and testing: Regular planning and testing reduce confusion and response time when security incidents occur.

At Tower 23 IT, we work with healthcare organizations across San Diego, Phoenix, and Tucson to turn HIPAA compliance into an ongoing process—not a once-a-year scramble.

Preparing Now for HIPAA SRA Readiness in 2026

To stay ahead of enforcement risk, healthcare practices should:

• Schedule SRAs proactively, not reactively: Proactive assessments help identify risks before they lead to incidents or regulatory scrutiny.
• Treat the SRA as a living document: Updating the assessment as systems and workflows change keeps compliance aligned with reality.
• Align IT operations with compliance requirements: Security controls are most effective when they are integrated into daily IT management, not layered on afterward.
• Partner with IT providers who understand healthcare regulations: Healthcare-focused expertise reduces compliance risk while allowing internal teams to focus on patient care.

This approach not only reduces regulatory risk, it strengthens security, uptime, and patient trust.

HIPAA SRA Compliance Support That Actually Works

HIPAA SRAs in 2026 are about accountability, follow-through, and real-world security—not paperwork alone. Practices that align compliance with daily IT operations will be far better positioned to withstand audits, cyber threats, and regulatory change. If your practice is evaluating managed IT service providers in San Diego, choose one that understands both healthcare workflows and HIPAA enforcement realities. Tower 23 IT can help you simplify HIPAA compliance while securing patient data—without overburdening your staff. Schedule your free compliance consultation today.