HIPAA Refresher Training

HIPAA Refresher Training is an annual course designed for staff who have already completed full HIPAA training and need their knowledge reinforced and updated rather than retaught from scratch. It is one of the most important tools for keeping HIPAA awareness alive in day to day work instead of letting it fade after onboarding.

What is Annual HIPAA Refresher Training?

Annual HIPAA Refresher Training focuses on reinforcing and updating knowledge that employees already have. It assumes that staff have previously completed a comprehensive HIPAA onboarding course and already understand core concepts such as PHI, ePHI, the Minimum Necessary Standard, and basic incident reporting. The aim is to strengthen good habits, correct small misunderstandings, and bring everyone up to date with new risks, tools, or policy changes. Because it is built on an existing foundation, the training can concentrate on real scenarios and common pitfalls rather than spending time on basic definitions. For that reason, it is only recommended for staff who have already received a complete, initial HIPAA training program.

How Often Should HIPAA Refresher Training be Provided?

HIPAA itself requires that training be provided on a regular basis, but it does not set a specific schedule. In practice, best practice in the healthcare sector is to provide HIPAA training annually, and the annual course is usually delivered in the form of refresher training. This creates a simple, predictable rhythm that is easy to communicate and easy to document. When everyone knows they will receive HIPAA training every year, it is easier to keep expectations clear and to avoid long gaps where habits drift away from policies. An annual cycle also lines up well with other compliance activities such as risk assessments, policy reviews, and security updates.

When is HIPAA Refresher Training Appropriate? (And when is it Not?)

Refresher training is not a replacement for full onboarding. It is not recommended for new staff because HIPAA Covered Entities and HIPAA Business Associates do not know each person’s baseline knowledge and must establish a consistent standard through comprehensive initial training. The refresher course should build on that baseline, not guess at it. Refresher training is also not suitable after a HIPAA violation. Employees who commit a HIPAA violation should receive more extensive HIPAA Remediation Training that looks closely at what went wrong, why it happened, and what must change, rather than a general refresher. In addition, refresher training is not enough for certain groups such as healthcare students, who should receive full HIPAA training that includes student specific content at the start of each placement. In short, refresher training works best for staff with solid prior training and a generally compliant track record.

HIPAA Refresher Training Content Recommendations

Even though HIPAA Refresher Training is shorter than onboarding, it still needs to cover specialist topics for the organization. For example, EMS staff should receive training on HIPAA in Emergency Situations every year, because their work regularly involves high pressure decisions about disclosures in complex environments. Refresher training is also the ideal place to introduce new topics that were not covered in the original course. Recent examples include HIPAA and AI tools, new communication platforms, and updated workflows for remote work. As technology and practice evolve, refresher training ensures staff understand how HIPAA applies to new tools and situations. Alongside HIPAA content, annual cybersecurity training is very strongly recommended, so staff are reminded about phishing, passwords, device security, and other threats that can expose electronic PHI.

Benefits of HIPAA Refresher Training

Annual HIPAA Refresher Training delivers clear, practical benefits. It reduces the risk of accidental HIPAA violations by reminding people about common pitfalls such as talking about patients in public areas, mishandling emails and attachments, or viewing more information than they need in electronic records. It keeps HIPAA on people’s radar in a busy clinical and administrative environment where urgent tasks can easily crowd out long term obligations. It also gives leadership a visible way to show their ongoing commitment to patient privacy and information security, rather than letting HIPAA compliance fade quietly into the background.

HIPAA Compliance Value of Annual Refresher Training

Annual refresher training also has significant compliance value. Completion records create a clear documentation trail that shows training is ongoing, not a one time event at hire. In the case of a HIPAA violation or an external investigation, these records support client due diligence, internal audits, and regulatory reviews by proving that the organization invests in regular, structured HIPAA education for its workforce. Consistent annual training makes it easier to demonstrate that the organization is acting in good faith, responding to new risks, and taking reasonable steps to prevent violations. It also helps identify departments or locations that may be falling behind on training, so corrective action can be taken before gaps turn into findings. Over time, a well documented pattern of annual refresher training strengthens the organization’s overall compliance posture and supports a more defensible response if something does go wrong.

What Features Should Be Included In HIPAA Refresher Training?

HIPAA Refresher Training should do more than repeat the onboarding course in a shorter format. It needs features that help staff update what they know, correct drifting habits, and stay aligned with current risks and expectations.

Training Created And Overseen By HIPAA Experts

Refresher training should be designed and maintained by HIPAA subject matter experts, including people who have experience as HIPAA Privacy Officers or Compliance Officers. Expert oversight helps ensure the content focuses on real world risks, common violation patterns, and practical behaviors rather than abstract legal language.

Current And Regularly Updated Content

Because refresher training is often taken annually, it must be reviewed and updated regularly. The material should reflect recent guidance, enforcement patterns, and changes in technology such as remote work tools, cloud platforms, and AI. Staff should come away knowing how HIPAA applies to current systems and workflows, not just how things used to work.

Employee Focused, Practical Curriculum

The curriculum needs to speak directly to employees. Refresher training should use simple language, clear explanations, and realistic scenarios that match clinical, administrative, and technical roles. It should highlight non compliant behaviors that cause real incidents, such as unattended workstations, unapproved file sharing, or oversharing in electronic records, and show what staff should do instead.

Emphasis On Risk Reduction And Modern Threats

A strong refresher program is organized around risk reduction. It should revisit high risk situations such as social media use, insecure messaging, and hurried communication in busy environments. The content should also reinforce how HIPAA applies in emergencies and unusual situations so staff can act quickly without guessing when pressure is high.

Flexible Overlays For Different Roles And Settings

HIPAA Refresher Training works best when it can be tailored to different roles and locations. The core course can be the same for everyone, while optional overlays add content for specific needs such as state medical privacy requirements, mental health or EMS practice, healthcare students, Business Associate staff, or small medical practices. This keeps the training relevant without having to build entirely separate programs.

Strong Documentation And Audit Readiness

Effective HIPAA refresher training includes solid documentation features. The system should record who completed which course, when they completed it, and what assessments they passed, with clear links to specific course versions. Reports should be easy to generate for leadership, clients, and auditors. This documentation shows that refresher training is ongoing, structured, and taken seriously across the organization.

Annual HIPAA Training is Healthcare Sector Best Practice

Annual HIPAA Refresher Training is most effective when it is treated as a focused annual update for staff who have already completed full onboarding, not as a shortcut or replacement for comprehensive training. Used correctly, it reinforces existing knowledge, addresses new risks such as changing technology and working practices, and keeps staff alert to common pitfalls that can lead to accidental violations. It is best reserved for employees with a solid baseline and a generally compliant track record, while new hires, healthcare students, and staff involved in violations should receive more extensive training that fits their circumstances.

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Staff are the Weakest Link in HIPAA Cybersecurity

Staff are the Weakest Link in HIPAA CybersecurityThe Department of Health and Human Services (HHS) Office for Civil Rights (OCR) data breach portal shows that patients’ protected health information is being exposed and stolen at an unprecedented rate. From 2021 to 2024, more than 700 large healthcare data breaches were reported each year, and each of those data breaches affected at least 500 individuals, with an average breach size of 203,892 individuals. In those four years alone, the protected health information of more than 595 million individuals was compromised.

Hackers have been targeting the healthcare and public health sector with increasing frequency, and hacking and other IT incidents now account for the bulk of the reported healthcare data breaches. Email accounts are accessed, networks are compromised, and in almost all cases, healthcare data is stolen by unauthorized individuals. While unauthorized third parties are the ones that access the data, when you delve into the root cause of the breach, it is often the actions of a healthcare employee or an employee of a business associate that caused the data breach.

Healthcare employees are the weakest link in cybersecurity and are targeted by cybercriminals directly, although in many cases, the actions of employees leave a digital door open for cybercriminals walk straight through. Carelessness, employee errors, poor judgment, and a lack of knowledge or understanding of good cyber hygiene result in serious patient privacy violations and costly data breaches. The most common mistakes made by employees usually result in relatively small privacy breaches; however, even these small incidents can cause considerable damage to a healthcare organization’s reputation, and the HHS’ Office for Civil Rights has imposed many fines on HIPAA-regulated entities for data breaches resulting from employee mistakes.

Employee-Related Cyberattacks & Data Breaches

Various studies have confirmed the risk posed by employees. For example, Verizon found that 70% of healthcare data breaches are caused by insiders, a considerable increase from the 39% of breaches in 2021 that were attributed to healthcare employees. A HIMSS survey made it clear that employees are the biggest vulnerability in healthcare, and another revealed that 65% of healthcare employees are taking security shortcuts that are putting patient data at risk, with employees’ poor cyber hygiene a persistent threat.

Listed below is a selection of the many healthcare data breaches caused by employee mistakes, carelessness, and poor security practices over the past five years. These attacks have resulted in the theft of millions of patient records, lawsuits, and HIPAA violation penalties.

Responses to Phishing Emails and Social Engineering Attacks

Employees falling for phishing emails led to $600K fine for a California health care network

Phishing campaign tricks 53 Los Angeles County employees into providing cybercriminals with access to their email accounts

Employee responds to malicious email and exposes 108K individuals’ PHI

Eleven Aveanna Healthcare employees divulge their credentials to cybercriminals in a phishing campaign

Illinois Department of Human Services employees fall for phishing emails, exposing the PHI of 1.1 million patients

Screen Actors Guild – American Federation of Television and Radio Artists sued after an employee responded to a phishing email

$200,000 penalty after a skilled nursing facility employee responds to a phishing email and exposes 14,500 individuals’ PHI

23 L.A. County employees duped by phishing emails and disclosed credentials

OCR imposes its first financial penalty in response to a phishing attack on healthcare employees

Henry Ford Health employees tricked by phishing emails, exposing 168,000 patient records

Office of the Attorney General of Massachusetts fines home health agency $425K for phishing attack, citing insufficient security awareness training

An EyeMed Vision Care employee’s response to a malicious email exposed 2.1 million individuals’ PHI and led to a $4.5 million fine

BJC Healthcare settles data breach lawsuit stemming from three employees responding to phishing emails

Salinas Valley Memorial Healthcare System employees respond to phishing emails and expose patients’ data – the healthcare provider was fined $340,000 over the breach

Employee Malware Downloads Provide Access to Hackers

“Honest mistake” by an Ascension Health employee led to a ransomware attack and a 5.6 million-record data breach. The employee downloaded a malicious file from the internet and executed it, inadvertently executing malware

Summit Pathology and Summit Pathology Laboratories employee opened a malware-infected email attachment

A Behavioral Health Network employee downloaded malware that prevented access to patient data

An employee’s accidental malware download allowed a ransomware group to encrypt files

Employees’ Poor Cyber Hygiene and Bad Cybersecurity Practices 

Healthcare workers routinely expose patient data to ChatGPT, Google Gemini, and via Google Drive and Microsoft OneDrive

An email error by an employee of The Queen’s Health Systems in Hawaii results in the impermissible disclosure of thousands of patients’ PHI

A Bassett Healthcare Network physician was discovered to have transmitted patient data to unauthorized individuals and saved patient data on a personal storage device

An email error by an employee of Campbell County Health has resulted in the impermissible disclosure of the protected health information of patients

Misconfigurations and Carelessly Exposing Patient Data

Password protection was not added to a DM Clinical Research database containing 1.6 million clinical trial records

A New Jersey health technology company employee exposed 86,000 records online

A Gargle database containing approximately 2.7 million patient profiles and 8.8 million appointment records was exposed online due to an employee error

Employee error results in impermissible disclosure of Winter Haven Hospital patients’ data

Employee error results in the exposure of 12 million medical laboratory records

Employee misconfigures patient database, exposing 3.1 million patients’ records. The database was subsequently deleted by the destructive Meow bot

Business associate employee misconfigures server, exposing Fairchild Medical Center patients’ data

University of Washington Medicine sued after an employee misconfigures server, exposing 974,000 patients’ PHI

An Indiana Department of Health employee misconfigures COVID-19 contact tracing database, exposing the data of 750,000 individuals

Failure to configure authentication exposes 1 billion records of CVS website searches

Department of Veterans Affairs contractor misconfigures database, exposing sensitive records of 200,000 military veterans

An employee misconfigures a County of Kings Public Health Department web server, exposing 16,590 patient records

Employee fails to secure AWS S3 bucket, exposing breast cancer patients’ data and medical images

Misconfigured CorrectCare web server exposes PHI of hundreds of thousands of inmates

A Washington D.C. health insurance exchange’s 56K-record data breach was the result of human error

Failure to configure access controls results in the exposure of the COVID vaccination statuses of 500,000 VA employees

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Settlement Resolves Data Breach Litigation Against Falcon Healthcare-Interim Healthcare of Lubbock Texas

Falcon Healthcare, doing business as Interim Healthcare of Lubbock, Texas, a home care and home health care service provider, has agreed to settle class action litigation stemming from a hacking incident that was first identified in June 2022. An unauthorized third party had access to its computer network between April 29, 2022, and July 3, 2022, and downloaded the protected health information of 89,443 patients.

Data compromised in the incident included names, addresses, dates of birth, Social Security numbers, driver’s license numbers, health insurance information, diagnoses, lab results, medications, and treatment information. The affected individuals were offered complimentary credit monitoring and identity theft protection services; however, it took until April 25, 2025, before the affected individuals were notified about the data breach.

On May 1, 2024, a class action lawsuit – Dawn Rice v. Falcon Healthcare, Inc. d/b/a Interim Healthcare of Lubbock, Texas – was filed in the District Court of Lubbock County, Texas, seeking damages on behalf of a national class of individuals affected by the incident. The lawsuit claimed that the data breach could have and should have been prevented. The lawsuit asserted claims of negligence, negligence per se, breach of implied contract, breach of fiduciary duty, and unjust enrichment.

The defendant denied all claims and contentions in the lawsuit, including all claims of liability and wrongdoing. Following mediation, all parties reached an agreement on the material terms of a settlement. A settlement was determined to be the best outcome for all parties to avoid further legal costs and expenses and the uncertainty of a trial and related appeals.

The terms of the settlement have now been finalized and approved by a federal judge. Falcon Healthcare has agreed to establish a $800,000 settlement fund to cover attorneys’ fees and expenses, settlement administration and notification costs, a service award for the class representative, and two years of medical data monitoring for the class members.

Class members are entitled to claim one of two further benefits. A claim may be submitted for reimbursement of documented, unreimbursed losses due to the data breach up to a maximum of $5,000 per class member. Alternatively, class members may claim a cash payment, which is estimated to be $100 per class member. These benefits will be subject to a pro rata adjustment based on the number of claims received. Further information can be found on the settlement website: https://falcondatasettlement.com/

The deadline for exclusion from the settlement and objection is January 20, 2026. All claims must be submitted by January 26, 2026, and the final fairness hearing has been scheduled for February 10, 2026.

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