Introduction

So maybe you’re a manager or compliance officer, wondering how do I set up a compliant training program for my organization?  Or maybe you’ve just finished your first HIPAA training, and you’re wondering when do I get to do this again? Contrary to what you may see on the web, there is no legally mandated frequency for HIPAA training. It’s not that simple - but read on -  and we’ll give you the tools and knowledge necessary to determine what’s right for you or your team. (If you're still trying to figure out if you need HIPAA training at all, read Who Needs HIPAA Training? The Ultimate Guide for 2023)

HIPAA Background

The Health Insurance Portability and Accountability Act, better known as HIPAA, first came onto the scene in 1996. This groundbreaking legislation was primarily designed to protect patients' medical records and other health information provided to health plans, doctors, hospitals, and other healthcare providers. The purpose of HIPAA is to strike a balance between sharing information for patient care and safeguarding individuals' health information from unauthorized access. Over the years, it has evolved to address the increasing digitization of the healthcare sector, always keeping patients' data privacy and security at its heart.

Different for Security vs. Privacy Rules

The HIPAA compliance requirements are mainly divided into two key territories - the Security Rule and the Privacy Rule - and each one has its unique set of stipulations for training.

The Security Rule emphasizes the safeguarding of electronic PHI (ePHI). It mandates workforce training for both covered entities and business associates that ensures staff understand the security protocols in place and the integral role they play in protecting ePHI.  Staff should be retrained “periodically” (no definition is provided).

On the other hand, the Privacy Rule extends its protection to all forms of PHI, not just electronic. Training under this rule necessitates that the workforce be informed about the organization's privacy policies and procedures, and should be retaught whenever these policies undergo significant changes. With that said, the Privacy Rule training requirements technically only apply to the staff of covered entities, and not business associates. And arguably only apply to staff whose roles require them to interact with PHI.

In essence, while both rules converge on the need for some type of training, they diverge on the specifics of what that training should encompass.

“Flexible”

Flexibility is a key aspect of HIPAA's approach to training. The guidelines don't provide an explicit frequency but instead recommend training “as necessary and appropriate for members of the workforce to carry out their functions." HIPAA's flexibility comes from its belief in a tailored approach for every organization. With its purposeful lack of explicit training timelines, it encourages organizations to determine their own training schedules. This means you can create a training program that fits the specific needs of your team and work environment, whether that means more frequent reminders or deeper, less frequent sessions. This adaptable approach allows for a more comprehensive understanding of HIPAA requirements, ensuring that the focus remains on the protection of PHI in a way that best suits your organization's operations.

Security Rule vs. Privacy Rule

Let’s dive a little deeper into the training requirements under the Security Rule and the Privacy Rule. Understanding this will be key to understanding the extent to which HIPAA training is required by law, and to designing your own optimal HIPAA training program.

Security Rule Requirement

The Security Rule is a fundamental component of HIPAA, focusing primarily on the safeguarding of electronic Protected Health Information (ePHI). Its core mission is to ensure that healthcare organizations implement adequate administrative, physical, and technical safeguards to assure the integrity, confidentiality, and availability of ePHI.

In terms of training requirements, the Security Rule stipulates that all workforce members must undergo training on the organization's security policies and procedures. At a bare minimum, training should occur when an individual joins the organization and should be updated whenever there are changes in the security policies and procedures.

The goal of this training is to enable the workforce to understand the security measures in place, the threats to ePHI, and the potential consequences of breaches. By promoting an awareness of security risks, the Security Rule ensures that every member of the workforce becomes an active participant in the protection of electronic health information.

Privacy Rule Requirement

The Privacy Rule is another essential component of HIPAA, aiming to secure the privacy of all Protected Health Information (PHI), not just that which is in electronic format. It sets standards for when and how PHI may be used and disclosed, assuring that patients maintain significant rights over their health information.

In terms of training, the Privacy Rule mandates that all personnel within a covered entity who access or use PHI should be trained in the organization's privacy practices, policies, and procedures. This rule extends to every individual that is part of the covered entity’s workforce who access or use PHI for their role, whether or not they are paid by the entity.

This training should also take place within a reasonable time after the person joins the workforce, and it should be updated whenever there's a material change in the policies or procedures. The focus is on imparting a solid understanding of how PHI should be used and disclosed, and the rights patients have concerning their health information. Essentially, the Privacy Rule aims to create a culture of privacy protection throughout the healthcare organization.

Satisfying Both Requirements Easily

The trick to satisfying both rules is to create an effective, ongoing training program that addresses both the Security Rule and Privacy Rule requirements. Many organizations will design a single training built to satisfy the requirements of both rules, and will administer it annually. This can make for a simple and easy to administer training program that abstracts much of the complexity inherent in building and executing multiple parallel programs. This is typically the purview of the Privacy Officer (learn more about the roles and responsibilities of the Privacy Officer here).

The Case for Annual Training

Despite HIPAA's flexibility, most organizations stick with annual training, or even more frequently. There are a number of important reasons why.

Compliance is Part of the Culture

HIPAA compliance is about cultivating a culture of privacy and security awareness within healthcare organizations. Integrating HIPAA training into an organization's core values emphasizes the importance of treating sensitive health information with the utmost care and responsibility.

Cultivating a culture of compliance means that HIPAA's guidelines are not seen as external impositions but are seamlessly woven into the everyday fabric of work. Every process, from patient interaction to data storage, is designed with HIPAA's standards in mind. This approach doesn't merely make compliance a company policy but an inherent part of the organization's DNA.

Furthermore, it underscores the shared responsibility that every member of the organization has in protecting patients' health information. From the CEO to the office intern, everyone plays a crucial role in maintaining HIPAA compliance. Regular training serves to reinforce this message, ensuring that the importance of protecting sensitive health information is always front of mind.

Frequent HIPAA training helps to create a culture where HIPAA compliance is central.  And this not only helps healthcare organizations avoid hefty penalties but also builds trust with patients, reinforcing the perception that their sensitive health information is in safe and responsible hands.

Goal is to Minimize Breach Risk; Not Check the Box

The primary objective of HIPAA training isn't merely to "check the box" and fulfill a regulatory requirement. It's to actively reduce the risk of data breaches, ensuring that sensitive patient data remains as secure as Fort Knox.

Each data breach can potentially expose thousands of patients' private health information and incur substantial penalties, not to mention the damage to an organization's reputation. Effective HIPAA training equips employees with the knowledge and skills to prevent such breaches, transforming them from potential security risks into crucial components of the organization's security strategy.

Thus, HIPAA training should be seen as a proactive and essential step in fortifying the organization against data breaches, rather than just a regulatory hurdle to be overcome or something delivered in a reactive manner after a policy change or incident.

Most Organizations Train Their Personnel Annually

While HIPAA does not specify an exact training frequency, it's clear that most healthcare organizations err on the side of caution and choose to provide training on an annual basis. A 2020 survey found that approximately 82% of healthcare providers deliver HIPAA training to their employees yearly.¹ In establishing an effective compliance program, looking to industry peers can be an effective practice to ensure best practices are met.

Thus, despite the flexibility provided by HIPAA, the common practice leans towards annual training, balancing the need for regular updates with the practicality of training logistics. Learn more about the keys to success for HIPAA compliance here.

What to Expect in an Online Training

In 2024, it is clear that it is far and away easier to administer a HIPAA training program online than in person. Though not all online HIPAA training is created equal. Read on to learn more about what to look for in selecting a training provider for your personnel.

Bad Training: Steer Clear

Bad HIPAA training can be likened to a faulty alarm system – it gives the illusion of security but fails to deliver when it matters most. This kind of training often takes the form of dull, monotonous lectures or lengthy, complex documents that fail to engage the audience. It may ignore real-world scenarios or lack practical advice, leaving employees unsure of how to apply the principles in their daily work. Additionally, poor training tends to skim over the potential consequences of non-compliance, leading to an underestimation of the seriousness of HIPAA breaches.

Spotting Quality Training

Good HIPAA training, on the other hand, is like a well-oiled machine, seamlessly integrating with an organization's operations and helping to uphold its commitment to data privacy and security. It is engaging, easy to understand, and relevant to the workforce's specific roles and responsibilities. This kind of training uses real-world examples and interactive scenarios that help employees grasp how the rules apply in their day-to-day tasks. Additionally, effective training underscores the potential repercussions of non-compliance, driving home the importance of strict adherence to HIPAA guidelines. It’s not long for the sake of being long; content is chosen with care to maximize the value for training participants.

HIPAA Certificate

Although not legally required, most robust HIPAA training solutions will provide a certificate of completion at the conclusion of the coursework. This serves as proof that HIPAA training has been completed within the company mandated timeframe. How long does a HIPAA certification last, you might ask. Many platforms will claim their employee HIPAA certifications last either one year or two years. But the truth is that this is entirely up to your organization, as per above, each organization can set its own cadence for HIPAA retraining. Learn more about HIPAA certification here.

How to Train Online

There are many online platforms for HIPAA training. We may be a little biased, but we believe one of the best is TeachMeHIPAA.

TeachMeHIPAA Offering

TeachMeHIPAA offers comprehensive, easy-to-understand training that meets both the Security Rule and Privacy Rule requirements. Our video training content is engaging, and most importantly, has been designed to deliver impact to your organization. Every minute of training includes high value insight that will directly translate to a workforce that is effective yet cautious, and well versed in how to avoid breaches that can be costly for your organization.

Included in our platform, at no charge, is a tracking dashboard to monitor compliance with the training requirement within your organization, so that you can feel comfortable that nobody will slip through the cracks.

Learn more about our offering by clicking here.

Conclusion

In a nutshell, while HIPAA is "flexible" about training frequency, annual training is considered a best practice by many organizations. You can absolutely go about designing a training program internal to your organization that meets both Security Rule and Privacy Rule requirements. But TeachMeHIPAA, a tool for HIPAA training online, offers an easy and cost-effective solution for organizations to meet their training requirements, and is configurable to a training cadence of your choosing (though we recommend at least annual!). Remember, the goal of HIPAA training is to protect sensitive information, so invest in a quality program that helps your organization do just that.

FAQs

How often is HIPAA training required? Is HIPAA training required annually?
There's no specified frequency in the HIPAA guidelines. It's recommended as necessary and appropriate for the workforce to perform their functions. Though the industry best practice is at least annually.

What is the difference between the HIPAA Security Rule and Privacy Rule?
The Security Rule focuses on the protection of electronic PHI, while the Privacy Rule addresses the protection of all PHI.

What does good HIPAA training look like?
Good training is engaging, understandable, and relevant. It should equip personnel with the knowledge they need to protect PHI, and isn’t just a check-the-box solution that wastes your time.

What is TeachMeHIPAA?
TeachMeHIPAA is an online platform offering comprehensive, easy-to-understand HIPAA training. It meets both the Security Rule and Privacy Rule requirements, is low cost, but delivers incredible value with free employee training status tracking built in.

Why is annual training recommended?
Annual training helps keep up with changes and continually reminds personnel of their responsibilities in protecting PHI. It's seen as a best practice by many organizations.