Many factors – both internal and external – can determine how long is HIPAA training good for, including regulatory changes, the introduction of new technologies, the outcome of a risk analysis, and workforce compliance. HIPAA training may also only be good for as long as an individual works for the same organization, as HIPAA policies and procedures should be unique to each HIPAA regulated entity.
The HIPAA training requirements provide two “timeframes” for how long is HIPAA training good for. The first – the HIPAA Privacy Rule training standard – states that “policy and procedure” training should be provided within a reasonable period of time of a person joining a covered entity’s workforce, and that “material change” training should be provided whenever there is a material change to policies and procedures that affects the person’s functions.
Material change training can be prompted by both internal and external events. For example, an organization may make procedural changes to the way in which patients’ rights requests are managed following a complaint. Alternatively, an organization may need to change its policies for disclosing PHI to third parties following the April 2024 amendment to the HIPAA Privacy Rule to support the privacy of reproductive health care information.
The second timeframe – in the HIPAA Security Rule training standard – is less specific inasmuch as covered entities and business associates are required to implement a security training and awareness program that includes periodic security reminders. However, this standard may soon be amended to mandate annual security awareness training, plus periodic reminders, plus further training whenever new technologies are implemented.
Other Factors that Influence How Long is HIPAA Training Good For
Other factors that influence how long is HIPAA training good for include periodic nontechnical evaluations and risk analyses (required by §164.308(a)(8) and §164.308(a)(1)), workforce sanctions (required by §164.308(a)(1) and §164.530(e)), regulatory sanctions, and whether an individual changes roles within an organization, or leaves an existing role to work for a different covered entity or business associate.
If a periodic nontechnical evaluation or a risk analysis identifies a vulnerability that exposes the privacy and security of PHI to compromise, the covered entity or business associate is required to resolve the vulnerability by implementing appropriate administrative, technical, or physical safeguards (§164.530(c)). As around 80% of healthcare data breaches allegedly involve a human element, the most likely safeguard is HIPAA training.
HIPAA training is also commonly used as a Tier 1 or Tier 2 workforce sanction for violations of HIPAA – even violations of standards that may not have been covered in HIPAA training – or as part of a “corrective action” following the notification of a data breach to HHS’ Office for Civil Rights. HHS’ Office for Civil Rights reported that 674 organizations had adopted correct actions during 2022 in its most recent report to Congress.
How long is HIPAA training good for is also subject to changes in roles or changes in employers. In the first instance, an individual might have to take additional HIPAA training to upgrade their HIPAA knowledge. In the second instance, the individual will have to be trained on their new employer’s HIPAA policies and procedures and security safeguards, as each HIPAA-regulated entity is required to implement unique HIPAA policies and procedures.
How Long is Certified HIPAA Training Good For?
In addition to in-house HIPAA training, some HIPAA-regulated entities outsource HIPAA basics training to third party vendors that offer a certification on completion of an online training course. HIPAA basics training has the advantage of ensuring that all members of the workforce have a baseline knowledge of HIPAA which can help them better understand and apply policy and procedure training and/or security awareness training.
Individuals can also subscribe independently to a certified HIPAA training course to enhance their employment prospects or to take responsibility for their own level of HIPAA knowledge. In these circumstances, how long certified HIPAA training is good for varies according to the terms of the course. Some courses also offer Continuing Education Units (CEUs) which may be good for up to three years depending on the terms of the licensing body.
However, when subscribing to an online HIPAA basics training course, the most important considerations are not necessarily that the course offers a certificate on completion of the course. It may be more important to ensure that the course is accredited by a recognized training assessor (i.e., AHIMA) and that the course content aligns with a current or future employer’s workplace policies and procedures.
Organizations considering a certified HIPAA training course are advised to evaluate free trials whenever possible to ensure the course content aligns with their policies and procedures, while individuals are advised to discuss the benefit of subscribing to an online HIPAA training course with a current or prospective HIPAA Privacy Officer to ensure that the HIPAA training curriculum is suitable for purpose.