How evolving scope and safeguards affect legacy data platforms
By Dan Kompare
In my role overseeing security and compliance architecture at Harmony Healthcare IT, I focus on translating evolving regulatory requirements into platform‑level protections that healthcare organizations can rely on over time.
As Chris Morrison, our Director of Governance and Compliance, outlined in a companion piece, the proposed updates to the HIPAA Security Rule reflect a clear shift in how regulators are thinking about scope, safeguards, and consistency across systems that store or touch electronic protected health information (ePHI).
The table below builds on that context by highlighting what these changes mean for healthcare organizations, and how Harmony Healthcare IT supports compliance, particularly around legacy data archiving
Aligning Legacy Data Platforms with the Proposed HIPAA Security Rule
For more detail on the proposed changes, read “HIPAA Security Rule Changes: 4 Key Implications”
| Proposed Rule Focus Area | What it Means for Healthcare Organizations | How Harmony Healthcare IT’s Secure Archiving Approach Helps |
|---|---|---|
| “Addressable” safeguards are substantially narrowed. | Broader, clearer scope across all systems that store or handle ePHI, reducing flexibility to defer or justify safeguards based on system role. Systems that may have been previously considered lower risk, such as legacy or archival environments, are less easily excluded from Security Rule expectations. | We treat archived and historical clinical data as fully in scope under HIPAA Security Rule expectations for ePHI. Baseline safeguards are applied consistently across archiving environments within a HITRUST r2 Certified, HIPAA‑compliant framework, aligned with the proposed rule. |
| Encryption and multi-factor authentication (MFA) extend beyond the EHR. | Clearer expectations that encryption and strong authentication apply wherever ePHI is created, received, maintained, or transmitted, with less tolerance for older or secondary systems that lack modern security controls. Environments that store historical or archived data are increasingly expected to meet contemporary standards for encryption and access controls. | We encrypt data at rest and in transit, support multi‑factor authentication (MFA), and enforce least‑privilege access with comprehensive audit logging—extending HIPAA‑aligned protections to archived and historical clinical data within a HITRUST r2 Certified, HIPAA‑compliant framework. We follow an even higher data standard than proposed in this rule. |
| Asset inventories and ePHI data flow visibility are required. | Clearer expectations for documented visibility into where ePHI resides and how it moves across systems, reducing reliance on informal knowledge or undocumented practices. Organizations are increasingly expected to maintain written asset inventories and data flow documentation that support accurate risk analysis—bringing legacy, archival, and secondary systems into clearer compliance view. | We consolidate historical data into secure archiving environments, reducing system sprawl and centralizing ePHI. This simplifies asset inventories, clarifies data flows, and supports ongoing risk analysis and audit readiness, already aligning with this proposed rule. |
| Availability and recoverability are core expectations. | Security expectations now extend beyond confidentiality and access controls to include ensuring ePHI remains available and recoverable during security incidents or operational disruptions. Systems that store historical or archived data are expected to support resilience and continuity, not just restricted access. | We operate within HITRUST and SOC 2 Type II–verified environments and support availability, resilience, and recoverability as core security principles, helping organizations preserve access to historical clinical data while supporting continuity and recovery planning. |
Putting the Proposed Changes into Practice
While the final HIPAA Security Rule may continue to evolve, the proposal offers a view into where enforcement is headed: broader scope and less tolerance for gaps across systems that store ePHI.
Platforms that centralize legacy and historical data into governed, secure environments can play a critical role in helping organizations respond to these shifts by simplifying visibility, strengthening safeguards, and supporting long‑term resilience as requirements evolve.
These expectations also carry added weight as more healthcare organizations apply AI‑driven tools across clinical, operational, and research use cases. AI depends on secure, well‑governed data environments where ePHI is protected consistently, access is controlled, and data provenance and flows are clearly understood. The same platform‑level safeguards that support HIPAA Security Rule compliance are foundational to using AI responsibly and at scale.
Dan Kompare is VP of Information Systems at Harmony Healthcare IT.
Note: This content reflects analysis of the HIPAA Security Rule as proposed at the time of publication. While final requirements may evolve, the themes outlined above reflect long‑standing Security Rule principles and clearly articulated enforcement priorities.
