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Cybersecurity · Security Testing

HIPAA never says 'penetration test.' Here is what it does say.

A covered-entity customer or an incident review will eventually ask the same thing: what evidence sits behind your risk analysis? The HIPAA Security Rule is deliberately technology-neutral. It requires an accurate and thorough risk analysis and a periodic technical and nontechnical evaluation of your safeguards, and it never once names a penetration test. A pentest is how the technical half of that evaluation gets real evidence behind it.

Independent quality engineering & cybersecurity since 2020, with 100+ security & quality engineers, delivering on platforms we build and run ourselves.

ePHI incidents carry regulatory scrutiny, notification duties, and the loss of patient and partner trust, and a risk analysis that never tested whether its own assumptions hold is the first thing that scrutiny lands on after an incident.

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What the Security Rule asks, and where a pentest fits

A risk analysis with evidence behind it

45 CFR §164.308(a)(1)(ii)(A) requires an 'accurate and thorough assessment of the potential risks and vulnerabilities' to ePHI. A penetration test replaces assumption with demonstration: which vulnerabilities can be reached, which can be exploited, and what data they expose.

The periodic evaluation, made technical

§164.308(a)(8) requires a periodic technical and nontechnical evaluation of how your security measures meet the Rule, repeated in response to environmental and operational changes. Recurring testing cycles give the technical side of that evaluation current, documented evidence.

Honest scope: no named test, no named cadence

The Security Rule mandates no specific test, frequency, or tool; it is deliberately flexible. That cuts both ways. Nothing forces you to run a pentest, and nothing specific shields you if you never did. We tell you what the Rule says and scope to your actual risk rather than to fear.

Scoped around ePHI

Testing shaped to where electronic protected health information lives and moves (patient-facing applications, APIs, integrations, and the infrastructure behind them), so findings map to the data your compliance program answers for.

How it’s delivered

  1. 01

    Scope

    Testing shaped around where ePHI actually lives and moves, agreed with the engineers doing the work.

  2. 02

    Test

    Manual assessment aligned to OWASP, PTES, and NIST SP 800-115 across the in-scope surfaces.

  3. 03

    Report

    Findings ranked by exploitability and by the data they expose, each with reproduction steps.

  4. 04

    Retest

    Fixes verified and the evidence updated for your risk-analysis file.

Tools & standards

Methodology
OWASP Testing Guide, PTES, NIST SP 800-115; retest policy standard
Framework
HIPAA Security Rule (45 CFR Part 164, Subpart C), a client-side requirement we test and report against; we are an independent testing partner, not a certification body
Team
Senior testers who have assessed healthcare and home-healthcare platforms; certifications across the bench include CISSP, CEH, and eCPPT

What you receive

  • An executive summary for leadership and compliance owners
  • Technical findings with reproduction steps, mapped to the ePHI they expose
  • Remediation guidance that weighs demonstrated exploitability over raw CVSS
  • Retest verification and an updated final report for your evaluation file

Engagement

Ways to engage the same senior bench

Buy it as a scoped project, embed it in your team, or run it as a managed service. The engineers and the governance stay the same, whichever shape fits.

Point-in-time assessment

One scoped assessment with a full report and one retest: for a release gate, a customer or audit requirement, or an annual baseline.

Standing program

Recurring cycles matched to your release cadence, each closed by a retest, so the newest report is never far behind the newest release.

On-demand scope additions

A new application, API, or environment joins the existing program without re-contracting; scoping starts in days.

Who this is for

  • Healthcare providers, digital-health, and telemedicine products holding ePHI
  • Business associates whose covered-entity customers ask for security-testing evidence
  • Compliance owners turning a paper risk analysis into a tested one

Common questions

Does HIPAA require a penetration test?

No. The words 'penetration test' appear nowhere in the Security Rule, and anyone citing a specific HIPAA pentest mandate is misquoting it. What 45 CFR §164.308 does require is an accurate and thorough risk analysis and a periodic technical and nontechnical evaluation of your safeguards. Penetration testing is a recognized way to put real evidence behind the technical side of that evaluation. That's the honest case for it, and the only one we make.

How often should we test?

The Rule sets no frequency; it requires evaluation periodically and in response to environmental or operational changes. In practice that maps to a cadence tied to your release and infrastructure change rate; we scope to how fast your environment changes, and skip the boilerplate calendar.

Is retesting included?

Remediation of reported findings is verified and the report updated to 'remediated and retested', the wording auditors expect. Retest scope and window are set in the engagement agreement.

Who actually does the work?

Senior engineers from our own bench: 63% hold industry certifications (CISSP, CEH, eCPPT, ISTQB, AWS). The people who scope your engagement are the people who run it; there is no rotating offshore bench behind the proposal.

How are our data and the findings handled?

Engagements run under NDA, and engineers who handle client data undergo background checks. Findings and reports are shared through channels agreed at scoping and are not retained beyond the period needed to deliver and support the engagement. Data-handling specifics (storage, encryption, retention, and destruction) are documented in your service agreement; see the Trust page for our posture.

One practice, one loop

This is one stage of a single assurance loop: findings become regression tests, and their indicators become live detections, so a problem, once fixed, can’t quietly come back. A stack of separate vendors has no way to close that loop. See how the loop connects →

Put evidence behind the risk analysis

Describe where ePHI lives in your systems and testing gets shaped around it, with reporting built for your evaluation file and your covered-entity customers.