Navigating HIPAA Compliance: Insights from North Country Communications
Published by DataBreaches.net in collaboration with North Country Communications, LLC. January 6, 2026
On December 15, North Country Communications launched as a consultancy aimed at equipping small and mid-sized HIPAA-regulated entities with the tools they need to adhere to HIPAA’s privacy, security, and breach notification requirements. In an exclusive interview, Rachel Klugman Seeger, the founder of North Country Communications, shared valuable insights on how her consultancy assists clients in navigating the complexities of HIPAA compliance.
Understanding Business Associates
Granularity of Client Consultation
Seeger highlights the granular nature of her consultancy’s work with clients. "HIPAA compliance is all about the details," she explains. By reviewing risk analyses, vendor contracts, encryption practices, policies, and audit logs, she tailors solutions to meet the specific needs of each client. Given that business associates often represent a weak link in data security, Seeger emphasizes the importance of strengthening oversight of third-party vendors.
Risks Posed by Business Associates
The findings from the Breach Barometer report produced by Protenus, Inc., illustrate a troubling statistic: while healthcare providers account for a significant portion of reported breaches, the records breached through business associates are far more substantial. Seeger agrees, stating, "The burden may lie with the covered entity, but the real impact often stems from third-party vendors."
Mitigating Breach Risks
To help clients avoid becoming part of disturbing breach statistics, Seeger emphasizes three key strategies:
- Conduct due diligence prior to contracting, ensuring strong business associate agreements.
- Require vendors to maintain documented policies and risk assessments.
- Regularly audit vendors and act upon findings.
In this context, accountability remains paramount; OCR will hold covered entities responsible for their business associates’ failures.
Navigating Breach Notification
Seeger advises that covered entities should maintain responsibility for notifying patients of breaches. "The patient’s relationship is with the provider or health plan— not the business associate," she asserts. This sentiment reinforces accountability and trust, which ought to be at the forefront of any breach communication strategy.
Website Compliance Checks
Importance of Website Reviews
Seeger reveals that websites are often overlooked in HIPAA compliance checks, yet pose significant risks. Misconfigurations can result in HIPAA violations, making it essential to review websites for adherence to both the HIPAA Privacy and Security Rules. Given the prevalence of crawlers and malicious bots, ensuring encrypted transmission is an absolute necessity, as unsecured transmissions can inadvertently leak ePHI.
Conducting Website Reviews
While Seeger performs initial compliance reviews that focus on HIPAA-specific risks, she encourages clients to work with specialized IT security firms for deeper penetration testing and remediation. This collaborative approach strives to ensure that technical safeguards are comprehensively addressed.
Emphasizing State Laws
Navigating State-Specific Regulations
Seeger points out that HIPAA serves as a federal baseline, but awareness of state-specific data security and breach notification laws is vital. Many healthcare organizations mistakenly assume that complying with HIPAA is sufficient. "In reality, state laws can impose stricter timelines and additional obligations," she warns.
Acknowledging Knowledge Gaps
Seeger observes that small and mid-sized organizations often lack a deep understanding of state regulations. She emphasizes that compliance programs must strengthen to fill those gaps, enabling organizations to understand their obligations and avoid unnecessary risks.
Understanding the HIPAA Privacy Rule
Cornerstones of the Privacy Rule
From her experience at HHS, Seeger identifies three critical aspects concerning the HIPAA Privacy Rule:
- Patients have the right to access their records quickly and affordably, emphasizing the Right of Access.
- The “minimum necessary” standard requires healthcare organizations to limit the exposure of individually identifiable information.
- Policies and procedures require integration into daily operations rather than existing as mere paperwork.
Common Pitfalls for SMBs
Seeger notes that treating HIPAA compliance as a checklist rather than a practical guide can lead to significant issues. "The most common failure is failing to train staff on real-world applications of policies," she explains.
Understanding the HIPAA Security Rule
Key Takeaways for SMBs
Seeger highlights three essential takeaways regarding the HIPAA Security Rule:
- Risk analysis must include a comprehensive review across the entire organization.
- While encryption isn’t explicitly mandated, it’s highly recommended.
- Administrative safeguards—such as workforce training—hold equal importance to physical and technical safeguards.
Addressing Misunderstandings
She’s also clear on the common misconception that simply investing in technology equals compliance. "Compliance is an ongoing, self-governing process," Seeger emphasizes.
The Breach Notification Rule
Importance of Timeliness
Seeger explains that timely notifications are critical in breach circumstances. Delays can magnify harm, both regulatory and reputational. She also stresses the need for clarity in communications, steering clear of jargon.
Common Mistakes in Breach Communications
Transparency and accountability are vital when notifying patients about data breaches. Seeger observes that failing to acknowledge responsibility is a missed opportunity to build trust with patients.
Looking to the Future
As organizations analyze their compliance structures, there’s a pressing need to remain vigilant as enforcement priorities shift. Seeger notes a significant increased focus on comprehensive risk analyses due to the rise in reported ransomware attacks.
The Future of Compliance
Seeger anticipates that businesses will need to revisit compliance strategies in light of evolving regulations. As OCR ramps up its enforcement efforts, she’d recommend that entities take proactive measures in adhering to both HIPAA and state-specific laws.
Note: Organizations are encouraged to explore resources available at North Country Communications and reference materials such as the handout on Navigating HIPAA’s Breach Notification & Media Reporting Requirements for further guidance.
