HIPAA Security Rule vs Privacy Rule: Essential Control Mapping for Healthcare IT Teams

What's the fundamental difference between HIPAA Security and Privacy Rules?

The HIPAA Privacy Rule governs how protected health information (PHI) can be used and disclosed, while the Security Rule specifically addresses the technical, administrative, and physical safeguards required to protect electronic PHI (ePHI). Understanding this distinction is crucial for healthcare IT teams implementing comprehensive compliance programs.

The Privacy Rule (45 CFR Part 160 and Part 164, Subparts A and E) establishes national standards for protecting individuals' medical records and PHI. It applies to all forms of PHI, whether electronic, paper, or oral. The Security Rule (45 CFR Part 164, Subpart C) focuses exclusively on ePHI and mandates specific safeguards for its protection.

How do Security Rule safeguards map to Privacy Rule requirements?

Security Rule safeguards directly support Privacy Rule compliance by providing the technical infrastructure to enforce privacy protections. The mapping follows three primary safeguard categories:

Administrative Safeguards:

• Security Officer designation (§164.308(a)(2)) supports Privacy Rule's administrative requirements (§164.530)
• Workforce training (§164.308(a)(5)) aligns with Privacy Rule training mandates (§164.530(b))
• Access management (§164.308(a)(4)) enforces minimum necessary standards (§164.502(b))

Physical Safeguards:

• Workstation controls (§164.310(b)) protect against unauthorized PHI access
• Device and media controls (§164.310(d)(1)) support Privacy Rule's accountability requirements

Technical Safeguards:

• Access control (§164.312(a)(1)) enforces Privacy Rule authorization requirements
• Audit controls (§164.312(b)) support Privacy Rule's accountability documentation
• Integrity controls (§164.312(c)(1)) protect against improper PHI alteration
• Transmission security (§164.312(e)(1)) protects PHI during electronic exchanges

Which Security Rule controls require Privacy Rule coordination?

Several Security Rule implementations directly depend on Privacy Rule policies and procedures. Healthcare IT teams must coordinate these interdependent controls:

1. User Access Reviews: Security Rule access control requires Privacy Rule minimum necessary determinations
2. : Security Rule audit controls must capture Privacy Rule compliance events