You Completed Your Security Risk Analysis—Now What?

Finishing a Security Risk Analysis (SRA) feels like a major milestone, and it is! It takes time, coordination, and effort to do it right.  The part that often gets overlooked from The Office for Civil Rights (OCR’s) perspective, is that completing the SRA isn’t the finish line. It’s the starting point.

What we’re seeing in enforcement right now makes that very clear. OCR isn’t just asking whether you completed an SRA anymore, they’re asking what you did with it.

In early 2026, OCR continued its Risk Analysis Initiative reaching at least 12 enforcement actions and still growing . In one recent case, a provider experienced a phishing attack that exposed patient data. But the bigger issue wasn’t just the breach itself, it was that the organization hadn’t done a thorough risk analysis or followed through with meaningful risk management.

So, what is the message from OCR?  It’s simple: An SRA without action isn’t enough.

Why This Matters More Than Ever

Cyber threats in healthcare aren’t slowing down.  They’re getting more frequent and more sophisticated. OCR has been very direct with their message that you can’t protect patient data if you don’t understand your risks and actively work to reduce them.

The HIPAA Security Rule doesn’t stop at requiring a risk analysis. It also requires organizations to manage those risks, to actually do something about what they find. This is where many organizations unintentionally fall short. The SRA gets completed, but the corrective action plan, the part that really drives security improvements, gets delayed or pushed aside.  From an enforcement standpoint, that’s a problem.

If you’ve completed your SRA, the most important question to ask is simple:
Are we actively working on our corrective action plan?

Here are a few practical ways to move forward:

• Focus on what matters most.
  Start with your highest-risk findings, things like email security, access controls, and system monitoring. You don’t have to fix everything at once, but you do need to start somewhere.

• Assign clear ownership.
  Every action item should have someone responsible for it. Without ownership, even the best plans tend to stall.

• Set realistic timelines.
  OCR doesn’t expect everything to be fixed overnight, but they do expect to see steady progress.

• Document your progress.
  This is critical. If you ever have to demonstrate compliance, you need to show not just what you identified, but what you’ve done about it.

• Make it part of your routine.
  Risk management shouldn’t happen once a year. It should be part of your ongoing compliance and IT discussions.

Completing your SRA is an important step, but it’s only part of your compliance program.

What OCR is really focused on now is follow-through. They want to see that organizations are not just identifying risks but actively working to reduce them.  If your SRA is sitting on a shelf, now is the time to revisit it and start moving through your corrective action plan.