What Medical Practices Think They Have vs. What OCR Actually Requires
HIPAA binders have been used in the past, but usually lack proper documentation that is required.
What Practices Often Rely On:
“We have a HIPAA binder.”
- HIPAA binder purchased (often never opened, and plastic not removed)
- Policies printed once (often not completed)
- Annual training sign-in sheets (sometimes, these are lost)
- Generic risk analysis template (if they have even conducted a risk analysis)
- Business Associate Agreements (many of these are missing, or lack compliance documentation)
- Someone assigned as “HIPAA Officer” (most compliance officers have other responsibilities, and HIPAA never seems to be documented)
This shows intent, but intent is not proof.
What OCR Looks for During an Investigation:
“Show us your documentation.”
OCR does not ask if you tried.
They ask what you can produce, immediately.
- A current, systemwide risk analysis tied to your systems (not one that is copied from another practice)
- Evidence of ongoing risk management, not a one-time exercise
- Training records for each workforce member
- Signed BAAs with vendors that access ePHI
- Policies that match actual safeguards in place
- Proof documentation is maintained, reviewed, and updated
The Reality Gap (Where Most Practices Get Stuck):
Binder Mindset vs OCR Reality:
HIPAA is done – HIPAA is ongoing
Purchased policies – Policies are incomplete
Staff trained – Training must be current and documented
Risk analysis completed once – Risk Analysis must be accurate and updated
We’re too small – All sizes are fined
Why Binders Fail During Audits:
- Documents become outdated quickly
- No audit trail showing updates or reviews
- Training proof is incomplete or missing
- Risk analysis is generic, not practice-specific
- BAAs are unsigned, expired, or missing
- Hard to produce documentation on demand
If it can’t be produced, OCR treats it as if it never existed.
The Question Every Practice Should Ask:
If the OCR contacted us tomorrow, could we confidently produce everything they would request?
If the answer isn’t a clear yes, it may be time to rethink how compliance is managed.
How our HIPAA Keeper™ Closes the Gap
Guided, step-by-step HIPAA compliance process
Built-in risk analysis & risk management tools
Centralized storage for policies, BAAs, and training records
Documentation that aligns with OCR expectations
Ongoing maintenance instead of “set-and-forget” compliance
Binders show effort. The HIPAA Keeper™ shows proof.
Additionally, you will have a HIPAA security analyst to guide and assist you when you need help.
To find out where you stand with your compliance, schedule a free HIPAA checkup today at Aris Medical Solutions.
