SOC 2 for healthcare organizations: Benefits and compliance steps

Healthcare organizations operate under an extension of regulations, HIPAA being amongst the top, leaving little room to prioritize voluntary frameworks like SOC 2. 

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However, overlooking SOC 2 is a missed strategic opportunity as it offers structured, actionable security guidance that not only strengthens security and privacy posture but also facilitates HIPAA compliance.

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In this guide, you’ll learn why that’s the case and discover:

• The basics of SOC 2
• The framework’s benefits for healthcare organizations
• The relationship between SOC 2 and HIPAA
• Practical steps for achieving SOC 2 compliance

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What is SOC 2?

SOC 2 is an industry-standard compliance framework developed by the American Institute of Certified Public Accountants (AICPA) that outlines practices for how organizations should manage customer data and related systems to ensure secure and responsible processing, storing, and sharing.

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There are two types of SOC 2 attestation:

1. Type 1: Evaluates control implementation at a specific point in time
2. Type 2: Evaluates control design, implementation, and effectiveness over a longer timeframe (typically 3–12 months)

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Organizations often begin with a Type 1 attestation because it provides a faster, point-in-time validation of control design, including a good stepping stone for their future Type 2 audit to demonstrate operational effectiveness of those controls over time.

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While SOC 2 focuses specifically on service organizations, it’s industry-agnostic. It can be adopted by organizations in any sector, including healthcare.

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Why is SOC 2 beneficial for healthcare organizations?

SOC 2 brings structure to control definition based on the five Trust Services Criteria (TSCs) that can help healthcare organizations align with regulations like HIPAA. Since HIPAA can be highly interpretive and leaves a risk of guesswork, SOC 2 can help reduce potential ambiguities by offering more control structure and repeatable compliance processes.

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The SOC 2 Trust Services Criteria (TSCs) include:

1. Security (mandatory)
2. Availability
3. Confidentiality
4. Processing integrity
5. Privacy

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Organizations can tailor their reports by selecting TSCs that are most relevant to their operational and compliance needs, especially important when aligning with HIPAA’s Security, Breach Notification, and Privacy Rules. Regardless of which TSCs you choose, many SOC 2 controls can be mapped to HIPAA due to a notable overlap between the two frameworks.

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Can SOC 2 help you meet HIPAA requirements?

SOC 2 can support HIPAA compliance by directly mapping the controls from some of its TSCs to HIPAA’s requirements.

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For example, the Security and Privacy criteria align closely with HIPAA’s Security and Privacy Rules, which helps your organization meet core obligations under both. A commonly implemented SOC 2 control requires the encryption of sensitive data in transit and at rest, which is also a safeguard required by HIPAA’s Security Rule.

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SOC 2 compliance can also help your organization comply with HIPAA’s Breach Notification Rule by requiring organizations to develop a structured incident response plan that enables swift breach detection and remediation. To fully comply with HIPAA, you must also address regulation-specific incident management requirements, such as submitting a notification letter to the HHS Office for Civil Rights within 60 days of discovering a breach.

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For companies that handle protected health information (PHI) and must comply with HIPAA, SOC 2 can lay the groundwork for meeting key requirements. In particular, it’s an effective mechanism for aligning with the HIPAA Security Rule, which outlines how organizations must safeguard PHI. As a result, companies that achieve SOC 2 compliance are well-positioned to meet HIPAA obligations.”

Ethan Heller

GRC Subject Matter Expert, Vanta

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LinkedIn

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Due to this close alignment, SOC 2 can help clarify many of HIPAA’s more ambiguous requirements, helping your organization achieve compliance faster.

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Practical benefits of SOC 2 for healthcare organizations

Streamlined HIPAA compliance isn’t the only reason healthcare organizations should pursue SOC 2 compliance. Other notable benefits include:

• Demonstrable security: A SOC 2 report lets you demonstrate a solid data protection posture to stakeholders. It also proves your commitment to comprehensive security beyond mandatory regulations, which helps foster trust in highly regulated industries.
• Competitive advantage: SOC 2-compliant business associates can help accelerate alignment in vendor risk assessments and Business Associate Agreement (BAA) evaluations because there’s a reduced need for extensive security reviews during the procurement process.
• Avoiding HIPAA violations: SOC 2 can help you operationally address HIPAA requirements, including mechanisms for third-party audit, ultimately mitigating the risk of HIPAA violations and associated penalties.

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5 steps to SOC 2 compliance 

While the specific activities needed to achieve SOC 2 compliance depend on your organization’s security posture, the general process involves the following steps:

1. Scope relevant SOC 2 controls: Assess your environment to identify which SOC 2 Trust Services Criteria (TSCs) and associated controls are applicable, particularly those relevant to systems that store, process, or transmit protected health information (PHI) and other sensitive data. Pay close attention to data flows, asset inventories, and system boundaries to determine which components require protection and under what control requirements.
2. Map SOC 2 controls to other authoritative sources: After selecting your controls, map them to HIPAA and other relevant standards or regulations such as HITRUST or NIST 800-53. This helps you avoid duplicative work while pursuing compliance with different authoritative sources.
3. Conduct a gap analysis: Conduct a comprehensive compliance review to understand your technical, procedural, and administrative controls. Compare your current security and privacy posture to the selected SOC 2 controls to identify gaps, and then prioritize gaps according to urgency/importance.
4. Implement missing controls: Develop a gap remediation plan to prepare your organization for SOC 2 attestation. Execute the plan, and then find a third-party auditor who will conduct an external audit to validate that your controls are operating effectively.
5. Maintain your SOC 2 report: You need to undergo regular audits to maintain your SOC 2 standing, so schedule those audits in advance to ensure readiness. Document control implementation and collect evidence of compliance in advance to expedite external audits.

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Common SOC 2 compliance challenges for healthcare organizations

When pursuing SOC 2 attestation, healthcare organizations may face challenges such as:

• Limited experience with broader security controls: Because healthcare organizations primarily focus on meeting HIPAA requirements, they may lack the resources or expertise to implement the wider technical and administrative controls SOC 2 requires. This can make creating new policies, managing controls, and defining security responsibilities more challenging.
• Conducting thorough risk assessments: SOC 2 requires regular, comprehensive risk assessments to identify vulnerabilities across IT systems and processes. Without prior experience or the right tools, these assessments can be resource-intensive and complex.
• Formalizing third-party risk management: Managing vendor risks is critical since third parties that handle PHI must meet strict security and privacy standards. Healthcare organizations often need to establish repeatable processes to evaluate and monitor their vendors’ security and privacy practices.
• Implementing technical and administrative controls: Controls such as access management, incident response, and change management are essential but may not be fully developed in organizations without consistent implementation.
• Assigning clear management responsibility: SOC 2 demands clear accountability for security policies and procedures at the leadership level. Defining and communicating these roles can be challenging but is essential for ongoing compliance.

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Healthcare organizations can overcome many of these hurdles by automating time-consuming tasks like documentation, evidence collection, and compliance reporting. Leveraging a dedicated compliance automation platform helps streamline workflows, maintain audit readiness, and avoid laborious and repetitive tasks.

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Streamline SOC 2 attestation and healthcare compliance with Vanta

Vanta is a comprehensive trust and compliance management platform that expedites SOC 2 attestation through advanced automation and ongoing support. It removes countless hours from your compliance workflows and helps with successfully completing a SOC 2 attestation.

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The platform offers a dedicated SOC 2 product combined with over 375 integrations to help you create cohesive compliance workflows with minimal legwork. Some of the product’s key features include:

• Automated evidence collection
• Pre-populated system description template and pre-made workflow
• Seamless support for SOC 2 audits throughout the process
• Centralized visibility of security tasks

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Besides the SOC 2 product, Vanta also offers a robust HIPAA product aimed at clarifying the regulation’s requirements and helping you meet them more efficiently. Vanta automatically maps your existing controls across 35+ authoritative sources, letting you combine SOC 2 and HIPAA to achieve compliance without extensive or repetitive work.

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If you need a reputable SOC 2 auditor (for Type 1 or Type 2 reports), you can tap into Vanta’s partner network. It brings together numerous auditors you can choose from to find an assessor who will support your organization every step of the way.

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Schedule a custom demo of Vanta’s SOC 2 product to see it in action and learn more about its features.

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