Navigating Upcoming HIPAA Security Changes: A 2025 Guide for Montana Healthcare & Hospitals

Proposed HIPAA Security Rule updates demand proactive preparation. Discover how Big Sky Cybersecurity’s compliance and cybersecurity services can ensure your Montana healthcare practice or hospital meets the changing compliance standards.

The Health Insurance Portability and Accountability Act (HIPAA) is the cornerstone of protecting sensitive patient health information (ePHI) in the U.S. But as cyber threats adapt, so must practice and hospital defenses. Earlier in 2025, updates to the HIPAA Security Rule were proposed to build stronger protections against modern cyber risks. For Montana healthcare practices and hospitals, especially our smaller and rural providers, understanding and preparing for these changes is critical to not falling into non-compliance. 

This guide, brought to you by Big Sky Cybersecurity, breaks down the key proposed changes and offers practical steps your Montana practice can take now to prepare. Our specialized IT and cybersecurity services are designed to help our Montana healthcare clients navigate these changes with confidence.

Why Stronger Defenses? Understanding the Proposed 2025 HIPAA Security Rule Updates

In response to increasingly sophisticated cyberattacks and cybersecurity deficiencies identified during investigations, the Department of Health and Human Services Office for Civil Rights issued a Notice of Proposed Rulemaking (published January 6, 2025). These proposals aim to build stronger protections around ePHI.While the final rule is anticipated in late 2025 or early 2026 after the public comment period, the direction is clea. Healthcare practices should expect rigorous, less flexible, and stronger mandated security standards for all Covered Entities and Business Associates. This will directly impact compliance for Montana healthcare and hospitals.

Key Proposed Changes Impacting Montana Healthcare

1. No More “Addressable” vs. “Required”

• The Change: The proposal largely eliminates the distinction between “required” and “addressable” implementation specifications. “Addressable” safeguards, which offered flexibility for covered entities, were often misinterpreted as “optional.” This change makes virtually all safeguards mandatory.
• Impact on Montana Practices: This is a major shift. It demands universal implementation of safeguards that smaller or rural Montana practices might have previously addressed with alternative measures or not provided.

2. Mandatory Multi-Factor Authentication (MFA)

• The Change: MFA is proposed as mandatory for all access points to systems containing ePHI (on-premises, cloud services like Microsoft 365 or your EHR, and third-party platforms). MFA requires users to verify identity using at least two different credential types.
• Impact on Montana Practices: This directly targets unauthorized access from compromised credentials, a leading cause of healthcare data breaches. 

3. Encryption for All ePHI

• The Change: While long a best practice, the proposed rule explicitly requires encryption for ePHI, both when stored (“at rest” – e.g., AES-256) and when transmitted (“in transit” – e.g., TLS 1.2+).
• Impact on Montana Practices: Properly encrypted data is unusable if stolen by threat actors. Ensuring comprehensive encryption is vital for compliance in Montana healthcare.

4. Technology Asset Inventories & Network Maps

• The Change: Organizations must develop and maintain detailed inventories of all technology assets (devices, applications, systems handling ePHI) and network maps illustrating how ePHI flows through the network and systems. These need annual updates.
• Impact on Montana Practices: Understanding where ePHI resides and how it moves is foundational to risk management. 

5. Annual Audits

• The Change: The proposal requires healthcare organizations to conduct and document comprehensive internal audits of administrative, technical, and physical safeguards at least annually.
• Impact on Montana Practices: This formalizes regular self-assessment for continuous improvement. 

6. Detailed Documentation Requirements

• The Change: Expect more detailed records of Security Risk Analyses, implemented security measures, and justifications for any (limited) alternative approaches.
• Impact on Montana Practices: Thorough documentation is key. 

7. Breach Notification Timelines

• The Change: While current rules stand (notify HHS/individuals within 60 days for breaches affecting 500+), discussions have hinted at potentially faster timelines (e.g., 72 hours for large breaches).
• Impact on Montana Practices: Adhere to existing timelines but prepare for potentially quicker notification periods and prompt incident response.

Practical Steps for Montana Healthcare & Hospitals: Prepare Now with Big Sky Cybersecurity

Don’t wait for the final rule. Proactive preparation is essential for all Montana healthcare providers.

• Assume “Addressable” is “Required”: Review all safeguards. Plan for full implementation.
• Prioritize Universal MFA: Inventory systems and plan deployment. Big Sky Cybersecurity can manage this transition.
• Assess & Implement Encryption: Ensure ePHI is encrypted at rest and in transit.
• Start Asset Inventory & Network Mapping: This is time-consuming but crucial. Our IT services can simplify this for your Montana facility.
• Formalize Annual Audits: Plan for comprehensive internal audits.
• Bolster Documentation: Enhance the detail of your HIPAA records.
• Stay Informed: Monitor HHS/OCR announcements. Big Sky Cybersecurity keeps our Montana clients updated.

How Big Sky Cybersecurity Elevates HIPAA Compliance for Montana Healthcare

These proposed HIPAA updates demand dedicated resources and expertise, which can be challenging for Montana healthcare practices that have limited time, staffing, and cybersecurity knowledge. Big Sky Cybersecurity is your local Montana expert, offering specialized IT services and compliance solutions for healthcare and hospitals:

• HIPAA Readiness Assessments: We assess your current posture against these proposed changes, identifying gaps and providing a clear roadmap for compliance for your Montana practice.
• MFA & Encryption Implementation: Our team provides expert IT services for planning and deploying robust MFA and encryption across your environment.
• Asset Inventory & Data Mapping: We guide Montana hospitals and clinics through creating comprehensive asset inventories and network diagrams crucial for HIPAA.
• Managed IT & Security Services: Our ongoing support helps Montana healthcare providers meet demands for continuous monitoring, annual audits, and proactive security management.

Local Montana Expertise: We understand the unique operational context, IT needs, and resource considerations for Montana healthcare providers, from large hospitals to small rural clinics.

Conclusion: Proactive Preparation is Key for Montana Healthcare in 2025

The proposed 2025 HIPAA Security Rule updates signal a clear intent by HHS to mandate stricter cybersecurity standards. For Montana healthcare practices and hospitals, proactive preparation is essential. By understanding these proposed changes now and leveraging expert IT services from a trusted local partner like Big Sky Cybersecurity, you can better protect patient ePHI, ensure compliance, and build a more resilient practice. 

Is Your Montana Healthcare Practice or Hospital Ready for the changing HIPAA rules?

Don’t wait for the final rule to start preparing. Contact Big Sky Cybersecurity today for a consultation. Let our Montana-based HIPAA and cybersecurity experts help you understand these proposed changes and develop a practical roadmap to strengthen your compliance and security with tailored IT services.