Why MSSPs must align with HITRUST

An academic article from 2020 published in Healthcare titled "Healthcare Data Breaches: Insights and Implications" found a dramatic increase in hacking/IT incidents associated with healthcare data breaches between 2010 and 2019. The authors reported that of 850 hacking/IT incidents recorded during this ten-year period, 692 (about 81.85%) occurred in just the last four years (2016–2019). This pattern showed that hacking-related incidents surged sharply in recent years, making them the most significant and growing threat to healthcare data security.

A February 2024 report from the U.S. Office of the Director of National Intelligence found that ransomware attacks against the healthcare sector nearly doubled in 2023, causing significant disruptions to patient care, including delayed procedures and service outages, as well as heightened risks to sensitive health data.

In light of these escalating risks, covered entities have a clear responsibility not only to comply with HIPAA’s minimum security standards, but also to ensure that every Managed Security Service Provider (MSSP) they engage can demonstrate security practices that go beyond baseline compliance. In today’s threat environment, verifying that MSSPs exceed minimum HIPAA requirements is not optional, it is a fundamental obligation for safeguarding patient data and continuity of care. The proof of this commitment comes in the form of alignment or certification with the HITRUST CSF.

According to HITRUST’s official response to the National Institute of Standards and Technology (NIST) on critical infrastructure cybersecurity, healthcare organizations struggle to balance the breadth and depth of what should be done to mitigate cybersecurity risks with their significant limitations on skills, manpower, and budgets. Healthcare organizations face significant barriers when trying to strengthen digital and cybersecurity capabilities. For example, a 2023 NPJ Digital Medicine review found that infrastructure and technical limitations, workload pressures, and insufficient training are among the most common obstacles professionals face when adopting new digital technologies. These systemic barriers prove why healthcare organizations seek standardized, certifiable frameworks like HITRUST to bridge the gap between broad regulatory requirements and practical, risk‑appropriate controls.

Faced with these limitations, many healthcare organizations find themselves asking, when evaluating an MSSP, what proof exists beyond self-attestations and lengthy, inconsistent security questionnaires? HITRUST answers that question by offering a comprehensive, certifiable framework that converts HIPAA’s broad and often ambiguous mandates into specific, measurable security controls. Unlike HIPAA, which has historically permitted flexible “addressable” safeguards, the HITRUST Common Security Framework is prescriptive and unambiguous in its requirements.

Healthcare leaders and regulators recognize that HIPAA establishes the legal obligation to be “secure,” but HITRUST provides the architectural blueprint, and the independent certification process to prove it. Organizations that achieve certification not only strengthen their internal security posture but also gain the ability to streamline regulatory compliance across multiple standards, simplify third-party risk management, and meet the growing expectation from health systems and payers that HITRUST certification be a contractual requirement.

Learn more: Why HITRUST certification matters

HIPAA’s limitations as a security framework

While HIPAA was groundbreaking when enacted in 1996, its Security Rule was never intended as a comprehensive cybersecurity framework. Traditionally, its 18 standards and 36 implementation specifications offered flexibility by distinguishing between "required" and "addressable" safeguards, the latter often misunderstood as optional. However, a major update proposed in 2024 eliminates this distinction, clarifying that all security specifications are mandatory (with limited exceptions) to address modern cyber threats more effectively. This shift from flexible guidelines to explicit requirements represents a change in HIPAA’s approach, emphasizing continuous risk assessment, stronger technical controls like mandatory multi-factor authentication, and real-time security operations to protect electronic protected health information (ePHI) more thoroughly.

Nonetheless, four practical limitations continue to affect MSSPs tasked with delivering HIPAA compliant security services:

• Risk-based vagueness 

HIPAA instructs covered entities to apply “reasonable and appropriate” controls but rarely defines what “reasonable” means in specific technical terms. MSSPs inheriting ambiguous client environments struggle to demonstrate that their services meet an unspoken benchmark, even with the updated mandatory framework.

• No prescriptive testing rhythm

Unlike frameworks such as PCI DSS or FedRAMP, HIPAA does not dictate penetration-testing frequency, vulnerability scan depth, or control maturity levels. This leaves buyers exposed to widely varying security postures among vendors who all claim HIPAA compliance.

• Self-attestation culture 

HIPAA compliance largely depends on internal risk assessments and policy documentation, with external validation triggered mainly by OCR audits following breaches. Healthcare organizations view self-attestation as insufficient and seek more proactive assurance.

• Fragmented mapping to other standards 

Health systems must comply with multiple frameworks (NIST 800-53, ISO 27001, state laws), resulting in parallel control inventories with incomplete overlap. The resulting administrative burden is costly and often transferred onto MSSPs managing complex compliance landscapes.

This evolving regulatory environment proves the growing need for MSSPs to deepen expertise, enhance transparency, and adopt continuous monitoring to meet the increasing clarity and rigor of HIPAA's 2025 updates while navigating these longstanding operational constraints

The growing demand for HITRUST in healthcare

According to the HITRUST 2024 Trust Report, which summarizes industry adoption trends from 2023, over 80 percent of U.S. hospitals and 85 percent of health insurers now accept or require HITRUST assessments during vendor onboarding. Request for Proposals (RFPs) from major integrated delivery networks reflect this priority, with top‑50 systems often assigning a 10–15 percent scoring advantage to vendors that hold HITRUST certification. Even the Office for Civil Rights (OCR), despite HITRUST not being a regulatory mandate, has begun referencing HITRUST mappings during post‑breach corrective action plans, pointing to its usefulness as a benchmark for security assurance.

Why the HITRUST CSF matters

The HITRUST Common Security Framework (CSF) is a unified, risk-based control library that harmonizes more than 40 authoritative sources, including HIPAA, NIST SP 800-53, ISO 27001, COBIT, and GDPR. At the core of the framework is a dynamic scoping methodology that tailors requirements based on three categories:

• organizational factors, such as annual revenue and employee count 
• system factors, such as whether workloads run in the cloud or on-premises 
• the transaction volumes involved
• regulatory factors, such as applicable state laws or international jurisdictions

These criteria determine which of the more than 2,000 illustrative controls apply and at which maturity level, ranging from policy and process to implementation, measurement, and managed optimization. This flexibility allows a 20-person MSSP and a multinational managed detection and response (MDR) provider to both adopt the same framework while scaling their workloads appropriately.

Benefits of HITRUST over HIPAA alone

Unlike HIPAA, which provides broad and flexible requirements that can lead to inconsistent security outcomes, HITRUST delivers a structured approach with tangible benefits. Its risk-based depth assigns controls to five maturity levels, creating a continuous-improvement roadmap that matures with an organization’s security program. Because HITRUST certification requires assessments by an authorized third-party assessor, whose results are then subjected to HITRUST review, the certification provides verifiable assurance that carries far more weight than HIPAA’s reliance on self-attestation. Additionally, HITRUST offers a powerful regulatory path, as a single HITRUST assessment can simultaneously address HIPAA, the NYDFS Cybersecurity Rule, and even portions of the FTC Safeguards Rule, thereby reducing redundant audits. The framework also supports scalability, when new regulations such as the California Consumer Privacy Act or the 21st Century Cures Act emerge, HITRUST updates its control library so organizations and MSSPs are not forced to rebuild compliance programs from scratch.

Why MSSPs should align with HITRUST

Competitive advantage comes first, an MSSP with a HITRUST i1 or r2 certification often advances automatically to the shortlist in vendor evaluations. The 2025 Healthcare Cybersecurity Benchmarking Study, produced by KLAS Research, Censinet, and the American Hospital Association, stresses how healthcare organizations continue to struggle with vendor risk management, with supply chain security ranked as the lowest-performing area of coverage for the third consecutive year. Against this backdrop, health systems are turning to HITRUST as the most reliable way to verify a vendor’s security posture. Beyond market positioning, certification demonstrates a tangible commitment to security. HITRUST assessments validate governance structures, technical safeguards, and continuous monitoring processes, therefore clients gain confidence that an MSSP’s security program is truly in order, which reduces perceived vendor risk and accelerates deal closure.

HITRUST certification also lightens the heavy reporting burden during client audits and risk assessments. Large integrated delivery networks require annual vendor reviews, often forcing MSSPs to complete hundreds of custom questionnaires or endure time-consuming site visits. A single HITRUST validated assessment report can replace this entire process with a comprehensive, 400-page package accepted across multiple clients, freeing MSSP staff to focus on billable security work. Moreover, insurers reward HITRUST with policy discounts of about 25 percent, and when breaches do occur, the detailed control evidence packaged in the HITRUST portal helps accelerate claims processing. 

Paubox as a HITRUST-certified partner for MSSPs

A 2023 peer‑reviewed study of healthcare cybersecurity practices concluded that email compromise and phishing are “amongst the most common malware techniques” leading to major data breaches in hospitals and health systems. Yet encryption solutions often hinder clinical workflows, leading staff to bypass them.

Paubox’s cloud email platform is HITRUST CSF r2-certified, offering MSSPs a secure messaging solution that aligns with key compliance controls. Its automatic TLS-based encryption eliminates portals and plug-ins, streamlining workflows and reducing user friction. MSSPs can integrate Paubox to strengthen their HITRUST posture by satisfying CSF requirements for secure information exchange. The platform supports compliance documentation through monthly encryption logs and message tracking, and most deployments complete within 48 hours, enabling MSSPs to offer secure email as a rapid service add-on.

FAQs

What is an MSSP?

A Managed Security Service Provider (MSSP) is a third-party company that delivers security services like monitoring, threat detection, and compliance support for healthcare organizations.

What is a self-attestation?

Self-attestation means an organization claims they are compliant by documenting their policies and risk analyses without independent verification, unless audited after a breach.

What is a Corrective Action Plan (CAP)?

A CAP is a documented plan required when a security control does not fully meet HITRUST standards. Organizations must fix these gaps to maintain certification.