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Map Your PHI Risks — Master Risk Assessments and Threat Monitoring (Step 2 of 17)

  • Writer: Patient Protect Editorial Team
    Patient Protect Editorial Team
  • Apr 29
  • 3 min read

Updated: May 4

Why Mapping PHI Risk Matters

Most breaches don’t happen because of sophisticated hackers — they happen because practices don’t know where their sensitive data lives, who has access, or how it's being protected.

Step 2 graphic for HIPAA Compliance Series – Map Your PHI Risks, Patient Protect 2025
Step 2 of 17: Map Your PHI Risks — Identify Threats Before They Become Breaches

Mapping your PHI (Protected Health Information) risks is the foundation of a proactive HIPAA program. Without it, you’re flying blind — unable to detect vulnerabilities, document mitigation, or prove compliance when it counts. OCR expects every Covered Entity and Business Associate to:

  • Conduct formal risk assessments

  • Monitor threats continuously

  • Document all mitigation strategies

  • Reassess risk over time — not just once

If you haven’t documented your PHI risks in the past year (or if your assessment sits in a PDF, untouched), you’re already falling behind.

What Mapping PHI Risks Looks Like

A complete PHI risk map should include:

  • Where PHI is stored, transmitted, and accessed (EHRs, emails, mobile devices, cloud backups, paper records)

  • Who has access to what (role-based access control)

  • How PHI is secured (encryption, MFA, logging)

  • What risks exist (e.g., shared credentials, unencrypted devices, unsecured faxing)

  • How those risks are being mitigated (or not)

Required Actions to Comply with HIPAA

  1. Conduct a Full HIPAA Security Risk Assessment (SRA) — annually

  2. Conduct a HIPAA Privacy Risk Assessment — often overlooked but critical

  3. Implement continuous risk/threat monitoring — via audits, alerts, or systems

  4. Document mitigation strategies — what’s being done, by whom, and by when

  5. Perform quarterly mini-assessments — especially after adding new software, staff, or vendors

This isn't just best practice — it's explicitly required under 45 CFR §164.308(a)(1)(ii)(A)–(D).

Common Mistakes

  • Only doing one type of risk assessment (typically security only)

  • Completing assessments, but never updating them

  • Using generic templates with no real documentation of actual risks

  • Skipping post-assessment mitigation entirely

  • Not reassessing after major changes to staff, systems, or vendors

Helpful Resources for Risk Assessment

Resource

Description

Link

HHS Risk Assessment Guidance

Explains the scope and requirements for risk analysis under the HIPAA Security Rule.

OCR SRA Tool

A downloadable tool from the Office for Civil Rights to help small practices conduct a HIPAA Security Risk Assessment.

NIST SP 800-30

Risk assessment framework often used by larger health systems and compliance professionals.

Visualize Your ePHI Risks in Real Time

Knowing your risks is one thing — seeing them is another. That’s why we built the ePHI Data Flow Mapping Tool — a free, interactive resource that helps you visualize exactly how Protected Health Information (PHI) moves through your practice.

Interactive HIPAA data flow diagram showing high-risk and secure PHI pathways across email, SMS, EHR, cloud tools, and Patient Protect
This visual from Patient Protect's ePHI Data Flow Mapper illustrates how Protected Health Information (PHI) travels through various healthcare systems — including communication platforms, EHRs, cloud storage, and third-party vendors. Red dashed arrows highlight high-risk transmission paths (e.g., unencrypted email, SMS, and vendor connections), while solid lines point to secure data flows handled through Patient Protect. The tool allows clinics to pinpoint exposure points and assess vendor risk, supporting better HIPAA risk assessments.

From patient intake to billing and referrals, this tool reveals the hidden paths your data takes — including:

  • Communication systems (email, fax, SMS)

  • Third-party vendors (EHRs, billing software, cloud tools)

  • Internal touchpoints (front desk, nurses, providers)

By mapping these flows, you can identify vulnerable junctions and make smarter decisions about:

  • Risk assessment priorities

  • Vendor risk exposure

  • Technical safeguard gaps

  • Incident response strategies

Try the tool now to see how your data moves — and where it might be at risk: Map Your ePHI Flow


How Patient Protect Helps

Mapping risks shouldn’t require spreadsheets, PDFs, or confusing government tools. The Patient Protect Platform is design to help:

  • Complete both Security and Privacy risk assessments in minutes.

  • Track risks, assign mitigation steps, and monitor progress.

  • Schedule quarterly re-assessments automatically.

  • Build defensible HIPAA records.


Next Step: Step 3 — Build Bulletproof HIPAA Policies


Once you’ve mapped your risks, your policies need to reflect how you mitigate them.

Next up: Step 3: Build Bulletproof Policies → Check it out!

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