How To Get Your Healthcare Company SOC 2 Certified
A guide to preparing your healthcare company for SOC 2 certification
In today's rapidly evolving healthcare landscape, ensuring the security and privacy of patient information is essential. With the increasing reliance on technology, healthcare organizations must not only comply with regulations like HIPAA but also demonstrate their commitment to safeguarding sensitive data. This certification not only signifies adherence to stringent security standards but also serves as a beacon of trust for patients and stakeholders alike. Let's explore what SOC 2 certification entails, the distinction between SOC 1 and SOC 2, and how healthcare companies can prepare for their next HIPAA audit by obtaining SOC 2 certification.
What is SOC 2 Certification?
SOC 2, short for Service Organization Control 2, is a widely recognized standard developed by the American Institute of Certified Public Accountants (AICPA). It focuses on a service organization's controls relevant to security, availability, processing integrity, confidentiality and privacy of customer data. SOC 2 compliance demonstrates that an organization has robust systems and processes in place to protect sensitive information.
In healthcare, SOC 2 is the most relevant of the five sets of standards because of its close alignment with HIPAA security and privacy requirements. If you already comply with HIPAA regulations, then you shouldn’t have too much difficulty passing your SOC 2.
SOC 2 Certification vs. SOC 1 Certification
Before jumping into the specifics of obtaining SOC 2 certification, let’s compare the difference between SOC1 and SOC 2. Since you’re going for your SOC 2, then you already know what it takes to become SOC 1 certified. But what does that next level of security look like?
SOC 1 primarily focuses on financial reporting controls, commonly used for evaluating the effectiveness of controls at service organizations that impact the financial statements of their clients. Depending on the scope, there can be anywhere between 10 and 30 control objectives in a SOC 1 report. On the other hand, SOC 2 is more comprehensive, focusing on non-financial reporting controls related to security, availability, processing integrity, confidentiality and privacy.
How to Get SOC 2 Certified
Alright, now that we’ve covered the basics a bit, it's time to jump into the nitty gritty of SOC 2 compliance.
Achieving SOC2 certification involves several key steps:
Assess your current controls
Before embarking on the certification process, conduct a thorough assessment of your organization's current controls related to security, availability, processing integrity, confidentiality and privacy. Identify any gaps or weaknesses that need to be addressed to meet SOC2 requirements.
Security
There are five Trust Services Criteria, and “Security” is the only one required in a SOC 2 assessment. Within the Security Trust Services Criteria there are nine Control Components, each with multiple Points of Focus.
CC1: Control Environment
CC2: Communication and Information
CC3: Risk Assessment
CC4: Monitoring Activities
CC5: Control Activities
CC6: Logical and Physical Access Controls
CC7: System Operations
CC8: Change Management
CC9: Risk Mitigation
Each Point of Focus is required to have at least two control activities so that if one control activity fails, the Point of Focus is still supported by at least one other control activity. For example, a username and password combination supported by two factor authentication.
Availability
For healthcare organizations eyeing SOC 2 compliance, meeting the Availability Trust Services Criteria primarily involves aligning with the Administrative Safeguards of the Security Rule (§164.308). This means ensuring proper data backups, maintaining environmental controls for physical backups, implementing robust data recovery measures and ensuring systems can handle fluctuations in demand.
Confidentiality
The Confidentiality Trust Services Criteria focuses on safeguarding Protected Health Information (PHI) within healthcare systems. Key areas for healthcare organizations include properly classifying and retaining data, safeguarding sensitive information, encrypting data and securely disposing of data to avoid overlaps and duplications.
Processing Integrity
While this Trust Services Criteria has been updated to match the EU-US Data Privacy Framework and the EU’s General Data Protection Regulation, its core requirement remains unchanged: ensuring that data processing is accurate, complete, timely and authorized. This aligns closely with HIPAA’s Technical Safeguards for maintaining the integrity of PHI and merits thorough review.
Privacy
The Privacy Control Components and Points of Focus closely mirror HIPAA Privacy Rule standards, covering aspects such as privacy policies, management and breach notification. While not mandatory for achieving SOC 2 compliance in healthcare, adhering to the Privacy Trust Services Criteria is typically expected by business partners and regulators, making its inclusion important from a regulatory and reputation standpoint.
Define scope and objectives
Clearly define the scope of your SOC 2 certification and establish specific objectives aligned with the trust services criteria (TSC) outlined by the AICPA. Determine which TSC areas are relevant to your organization's operations and tailor your controls accordingly.
Implement necessary controls
Based on your assessment and defined objectives, implement the necessary controls to address the requirements of SOC2 certification. This may include implementing access controls, encryption measures, incident response protocols and data retention policies, among others.
Document policies and procedures
Document all policies, procedures and processes related to the controls implemented for SOC 2 compliance. Ensure that these documents are comprehensive, up-to-date and readily accessible to relevant stakeholders within your organization.
Conduct internal audits
Conduct regular internal audits to assess the effectiveness of your controls and identify any areas for improvement. Internal audits help ensure ongoing compliance with SOC 2 requirements and demonstrate a commitment to continuous improvement.
Engage a qualified auditor
To obtain SOC 2 certification, you'll need to engage a qualified third-party auditor to perform an independent assessment of your organization's controls. Select an auditor with experience in conducting SOC 2 audits for healthcare organizations and ensure they are accredited by the AICPA.
Perform readiness assessment
Before undergoing the official SOC 2 audit, consider performing a readiness assessment to identify any potential issues or gaps that may affect your certification. Address any findings from the readiness assessment to strengthen your readiness for the official audit.
Undergo SOC 2 audit
Once you're confident in your organization's readiness, undergo the official SOC 2 audit conducted by the qualified third-party auditor. The auditor will assess your controls against the relevant TSC areas and provide a report detailing their findings.
Address audit findings
If any deficiencies or areas for improvement are identified during the SOC 2 audit, promptly address them to ensure compliance with SOC 2 requirements. Implement corrective actions as necessary and work closely with your auditor to validate remediation efforts.
Obtain SOC 2 certification
You did it! Upon successful completion of the SOC 2 audit and addressing any audit findings, you'll receive a SOC 2 report from the auditor. This report provides assurance to your customers and stakeholders that your organization has implemented effective controls to protect their data, ultimately enhancing trust and credibility.
How can a SOC 2 certification help you with your next HIPAA audit?
In today's healthcare landscape, maintaining the security and privacy of patient information is crucial and a regulatory requirement. While HIPAA and SOC 2 requirements do differ slightly, achieving SOC 2 certification demonstrates your organization's commitment to safeguarding sensitive data and meeting industry-recognized standards for security, availability, processing integrity, confidentiality and privacy.
By following the steps outlined in this guide, healthcare companies can effectively prepare for their next HIPAA audit by obtaining SOC 2 certification, thereby enhancing trust, credibility and compliance with regulatory requirements.
At OpenLoop, we know keeping patient information safe is a top priority for every healthcare organization. Compliance is built into every one of our seven core service offerings. Our team of experts stay up-to-date on HIPAA laws and regulations, offering state-by-state regulatory and legal support to our clients. Additionally, our intuitive, HIPAA-compliant EHR platform offers the security and privacy you require with the customizability you want.
Interested in what we can do for your organization? Get in touch here!
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