Zero Trust and HIPAA

Ken Schwarz — CISSP, CISM, CGRC, ITIL • March 25, 2026

Because the Castle Walls are No Longer Enough

The next evolution of the HIPAA Security Rule is shaping up to be less about checking boxes and more about fundamentally changing how healthcare organizations think about risk and resilience. And if you’ve been hearing terms like “Zero Trust" thrown around, it’s not just industry noise. This concept is quickly becoming the baseline expectation rather than advanced security maturity.


At its core, Zero Trust is actually a simple idea, even if the technology behind it can get complex. For years, most organizations operated like a castle. If you were inside the castle walls (in the building logged into the system) you were trusted. The assumption was that threats came from the outside, and once someone got in they were largely free to move around. Zero Trust flips that thinking completely. It assumes that no one, inside or outside the network, should be automatically trusted. Every access request must prove itself, every time.


In plain terms, it’s the difference between leaving all the interior doors of your house unlocked because someone made it through the front door, versus requiring a key for every room. It might sound excessive at first, but in a world where over 60% of breaches result from stolen credentials and insider exploits, it’s a far more realistic model.


This is where multi-factor authentication, identity and access management, and network segmentation come into play. They aren’t separate initiatives anymore. They are the basic building blocks of a Zero Trust approach. Multi-factor authentication ensures that a password alone is no longer enough to access sensitive systems. Identity and access management governs who has access to what, and just as importantly, whether they still need that access today. Network segmentation limits how far someone, or something, can move within your environment, even if they do get in.


For small and mid-sized healthcare providers like care centers, clinics, and specialty practices, this shift can feel daunting. Many of these organizations have historically relied on outsourced IT support and legacy systems that were never designed with this level of security in mind. They're concerned how they implement something that sounds enterprise-grade without enterprise resources. This is understandable.


The reality is that Zero Trust is less about buying a single product and more about adopting a mindset. Most SME care centers are already partway there, whether they realize it or not. If you’re using cloud-based EHR systems, enforcing MFA for remote access, or limiting administrative privileges, you’ve already taken steps in the right direction. The upcoming expectations simply formalize and expand those practices.


What will change is the level of intentionality. Access will need to be more tightly defined, not just for clinicians and staff, but also for anyone else interacting with patient data. “Set it and forget it” user accounts will become a liability. Shared logins, which are still surprisingly common in some environments, will become increasingly difficult to justify. Networks that once operated as flat environments will need to be broken into smaller, controlled zones to prevent lateral movement.


For a care center, this doesn’t mean building a complex, military-grade infrastructure overnight. It means asking practical questions. Does every employee only have access to the systems and resources they truly need? Is MFA enforced everywhere it should be, not just at the perimeter? If a device is compromised, how much of the environment can it actually reach? If a staff member leaves, how quickly and completely is their access removed?


There’s also a cultural shift embedded in all of this. Security can no longer be seen as an obstacle to care delivery. It has to be part of how care is delivered safely. That requires clear communication with staff, not just new written policies. When clinicians understand that these measures protect patient safety just as much as they protect data, adoption tends to follow.


From a regulatory perspective, the direction is clear. The updated HIPAA Security Rule is moving toward requiring demonstrable, ongoing risk management rather than periodic compliance exercises. You know, the "compliance theater" I've frequently talked about. Zero Trust aligns perfectly with that goal because it is continuous by design. It doesn’t assume security based on past assessments. It continuously verifies it in real time.


For SME care centers, the takeaway isn’t that the bar is being raised beyond reach. It’s that the definition of “reasonable and appropriate safeguards” is evolving to match the constantly evolving threat landscape. And the easiest way to successfully navigate this is to start small, prioritize high-impact areas like MFA and access control, and build from there with a clear strategy.


In the end, Zero Trust isn’t about distrust for its own sake. It’s about acknowledging reality and designing systems that are resilient because of it. In healthcare, where the stakes are measured in both data and lives, that shift isn’t just inevitable. It’s necessary, and way overdue.

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