Checklist · For small practices

HIPAA Documentation Checklist for Small Practices

A practical list of every HIPAA artifact a small medical, dental, or behavioral health practice should have on file — what it is, why it matters, and what "good" looks like.

HIPAA documents workspace with folder tree and versioned document list
HIPAA documents workspace with folder tree, version numbers, and reviewer owners.

Administrative documentation

ArtifactWhat "good" looks like
Current Security Risk AnalysisScoped, dated within the last 12 months, with findings and risk rankings.
Risk Management / Remediation PlanEach finding has an owner, target date, and evidence of completion or progress.
HIPAA Privacy & Security PoliciesCustomized to the practice, versioned, signed off, reviewed annually.
Notice of Privacy PracticesCurrent, posted in the office, given to patients, and on the website if applicable.
Workforce Sanctions PolicyDocumented consequences for HIPAA violations, applied consistently.
Designated Privacy & Security OfficialsNamed individuals with documented responsibilities.

Workforce documentation

ArtifactWhat "good" looks like
HIPAA training recordsPer-user completion with date and certificate, refreshed annually.
Policy attestationsSigned acknowledgement that each workforce member received and read the policies.
Access provisioning recordsWho has access to which systems, granted when, by whom.
Termination / access removal recordsDocumented timely revocation of access when someone leaves.

Vendor & technical documentation

ArtifactWhat "good" looks like
Business Associate AgreementsSigned BAA for every vendor that touches PHI, current and findable.
Vendor risk reviewsDocumented review of significant vendors' security posture.
Endpoint inventory & encryption statusList of devices that handle PHI with encryption verified.
Vulnerability / patch evidenceScan results, patch status, and remediation of known-exploited CVEs.
Backup & disaster recovery recordsDocumented backups, test results, and recovery procedures.
Audit log review recordsEvidence that key system audit logs are reviewed regularly.

Incident & breach documentation

ArtifactWhat "good" looks like
Incident Response PlanWritten plan, with roles and contact information, tested at least annually.
Incident logEvery reported incident with classification, response actions, and outcome.
Breach risk assessmentsDocumented evaluation for each incident that may have involved PHI.
Breach notifications (if applicable)Records of notifications sent to individuals, HHS, and media as required.
Retention rule of thumb: the HIPAA Security Rule requires required documentation to be retained for at least six years from creation or the date last in effect, whichever is later. State laws may require longer.

Frequently asked questions

How long must HIPAA documentation be retained?

The HIPAA Security Rule requires that policies, procedures, and related documentation be retained for at least six years from the date of creation or the date last in effect, whichever is later.

Can HIPAA documentation be electronic?

Yes. HIPAA requires that required documentation be maintained in written form, which may be electronic. The key requirement is that it is accurate, current, available to those who need it, and produced on request.

What is the difference between policies and procedures?

Policies state what the organization does and why; procedures describe how the work is actually performed. Auditors expect both, customized to the organization.

What is the most-missed HIPAA documentation in small practices?

Risk management / remediation plans tied to the Security Risk Analysis, evidence of policy adoption, and training records with per-user proof of completion are the most commonly missing items.

Centralize your HIPAA documentation

HIPAA Security Suite puts every artifact on this checklist in one workspace, so producing your audit response package is a download, not a hunt.