HIPAA Breach Notification: The 60-Day Clock Starts Ticking Immediately
A Practical Guide for Rural Health Care Organizations
Covers 45 C.F.R. §§ 164.400-414 (Breach Notification Rule)
A Practical Guide for Rural Health Care Organizations
Covers 45 C.F.R. §§ 164.400-414 (Breach Notification Rule)
While the HIPAA Security Rule does not explicitly mention "software patching" or "updates," the HHS Office for Civil Rights (OCR) has established through enforcement actions that maintaining current, supported software is a required component of HIPAA compliance. The 2014 Anchorage Community Mental Health Services (ACMHS) settlement serves as the definitive precedent, with OCR explicitly citing the failure to apply patches as a Security Rule violation resulting in a $150,000 penalty.
As of October 14, 2025, Microsoft Windows 10 has officially reached its End of Life (EOL). If you're reading this while still running Windows 10, you're already at risk of noncompliance with HIPAA security requirements, and both Microsoft and the Office for Civil Rights (OCR) know it.
Picture this: Your 18-bed critical access hospital just received a HIPAA audit notice. Your IT manager turns pale. Why? Because you've been running on Microsoft 365 Business Premium, thinking you were saving money. What you're about to discover could be the difference between a clean audit and a compliance nightmare that costs your facility millions.
You've been placed in charge of disaster recovery planning at your rural health care facility. Maybe someone told you to "create our DRP." Maybe it landed on your desk because you're the IT person. Or maybe you drew the short straw at the last staff meeting.
Sounds easy, right?
Here's what nobody told you: You've just been handed a can of worms that touches every IT system, every compliance requirement, and every department in your organization.
In 2023, St. Joseph's Medical Center settled a HIPAA investigation for disclosing patient information to a news reporter [Source: HHS.gov Resolution Agreements]. In April 2025, PIH Health paid $600,000 after a phishing campaign exposed 189,763 individuals' PHI through compromised email accounts [Source: ChartRequest.com].
Microsoft's August 2025 Patch Tuesday update (KB5063878) presents healthcare organizations with a challenging risk assessment scenario. While the update addresses 107 critical security vulnerabilities—including an actively exploited zero-day—reports have emerged of storage drive failures under specific conditions.
This article contains tough love — but it comes from a place of deep respect and genuine concern. We know you're not in rural health care for the money — you could make more elsewhere. You're here because you care about your community. We share that mission, which is why we believe in giving you straight talk about risks and challenges.
How a Single Unchecked App Could Cost Your Health Care Organization Everything
You protect patient data every day. But do you know exactly what a HIPAA violation could cost your organization?