Updating Policies and Programs for Privacy Rule Changes

How to Update Your Privacy Program or HIPAA Risk Assessment Following the Vacated Privacy Rule Regulation

The 2024 Privacy Rule changes are included only in programs created on or after December 23, 2024. If your HIPAA Risk Assessment, HIPAA for Small Practices, or Privacy Program was created before that date, it does not contain the content reflecting the now vacated regulation.

Start a New Program and Import Answers

This option allows you to build a fresh version of the program while retaining your current answers, so you can easily identify and update areas impacted by the regulation change.

Create a New Program

• Navigate to your Programs tab.

• Click + New Program, and select Privacy Program or HIPAA Risk Assessment as appropriate.

Import Existing Answers

• When prompted, select the option to import from an existing program.

• Choose your current version to bring in previous responses.
  

Review Changes

• After import for the Privacy Program, use the Freshness sort option to bring controls marked with a blue flag to the top.

• These indicate material changes related to the vacated rule.

• Update your responses where necessary based on the new guidance.

In the HIPAA Risk Assessment or HIPAA for Small Practices programs, use the sorting feature to identify and update affected controls:

• Use the sorting option to bring questions or controls with existing answers (e.g., Met, Not Met, or Not Applicable) to the top.

• Questions or Controls that require review due to the regulatory change will have their previous answers cleared.

• These questions and controls can be reviewed and re-answered to reflect current requirements.

Policy & Manual Updates

• The Guard's templated policy manual and individual policy templates have already been updated to reflect this change. To apply the changes you can:
  

  • Adopt the new templates as-is, or

  • Use them as a reference to revise your existing materials.

To update existing individual policies in the Policy module, use the Filter option to apply the Privacy Rule 2024 tag to isolate the policies impacted by the change.

To find specific sections of the manual such use your keyboard's search function:

• On Mac: Press Command + F

• On Windows: Press Ctrl + F

Then, type "attestation" or "reproductive health" into the search bar. This will highlight and take you to the relevant portions of the manual.

If you have any questions or need assistance applying these updates, please contact your CSM or our support team at support@compliancygroup.com.