HITRUST 101: Answering Your Biggest Questions

By reading this, you’ll learn about the fundamental aspects of HITRUST certification, as well as receive answers to frequently asked questions about HITRUST.

Introduction

There are a number of important certifications or compliance requirements your company can achieve in regard to cyber and financial security (e.g., PCI DSS, HIPAA). One of the more high level and detailed certifications is HITRUST. This type of certification can ultimately set your business apart and place you into a higher level of security.

In this white paper, you’ll learn about the fundamental aspects of HITRUST certification, as well as receive answers to frequently asked questions about HITRUST, like: 

  • What are the benefits of obtaining HITRUST certification for your business? 
  • What does the HITRUST certification process look like? 
  • How do I know which HITRUST controls apply to my organization?
  • How do I prepare for a HITRUST assessment?
  • How do SecurityMetrics and Privaxi support customers in achieving successful HITRUST certification?

Let’s answer your biggest questions so you can tackle HITRUST with confidence.

What is HITRUST CSF?

HITRUST Common Security Framework (CSF) includes multiple security frameworks under one umbrella.

Like any robust security framework, HITRUST CSF helps reduce the risk of breaches and enhances early detection of potential threats, minimizing damage to your organization.

Do I need to have this assessment performed?

HITRUST is becoming increasingly required by organizations to ensure robust protection of sensitive data, such as personally identifiable information (PII) and protected health information (PHI), particularly when working with third parties, especially in the healthcare sector. 

For example, groups like Health3PT accept HITRUST certification as a trusted way to manage third-party risk effectively.

What are the benefits of obtaining HITRUST certification for my business? 

Obtaining HITRUST certification demonstrates your organization’s commitment to maintaining a comprehensive set of security and privacy controls tailored to your business. It signals to your partners and business associates that you prioritize data protection and have taken necessary steps to reduce risk.

Many organizations face the challenge of addressing multiple assessments, and HITRUST is beneficial as it maps to various other frameworks. However, despite its importance, many hesitate to pursue HITRUST certification due to limited resources and often only do so when required.

Large organizations in the healthcare sector often require HITRUST validation of their business associates and service providers to achieve assurance that these partners are committed to security and are taking necessary measures to secure the data entrusted to them.

Which type of HITRUST assessment do I need?

HITRUST offers several types of assessments, each focusing on different controls:

  • e1 assessment:
    A HITRUST e1 assessment, which stands for "Essential 1-year Validated Assessment," is a cybersecurity evaluation by HITRUST that focuses on an organization's compliance with foundational cybersecurity controls, designed to be a low-effort way for companies to demonstrate basic security practices, particularly suitable for startups or those with low-risk profiles.
    It is considered an entry-level assessment within the HITRUST framework, validating adherence to 44 critical security controls for a one-year period.
  • i1 assessment:
    The i1 assessment builds on the e1 by including its 44 controls plus additional ones, totaling about 182 controls.
    It focuses on leading cybersecurity practices and operates on a two-year cycle. In the first year, all 182 controls are reviewed, while the second year involves a rapid re-certification with only 60 controls, making it more cost-effective.
    This step-up assessment is suited for organizations aiming for enhanced security assurance.
  • r2 assessment:
    The r2 assessment is considered the gold standard for HITRUST, offering the most comprehensive coverage. It includes the controls from the e1 and i1 assessments and adds any additional controls applicable to your business.
    The number of controls varies based on your organization’s complexity, typically ranging from 200 to over 2,000. 

Before starting an r2 assessment, a detailed analysis of your company’s attributes is required to determine the scope. This assessment is ideal for organizations seeking the highest level of security assurance.

Where the e1 and i1 are built with a preset set of controls, the r2 incorporates all of the controls contained in the e1 and i1, but then adds additional controls, which are determined by your completion of the factoring exercise in the MyCSF portal. 

This exercise consists of a questionnaire about your business’ functions and scope, along with selecting the various standards you wish to include (e.g., State of Texas, HIPAA, FedRAMP).

Choosing the right certification depends on your business needs, risk appetite, and level of maturity. Budget and resources also play a significant role in determining the necessary controls. Understanding your risk level and limitations is crucial in making the right choice.

Timing of your deliverable requirements may also inform your decision regarding which of the three assessment types would be smart.

As far as cost goes, the MyCSF portal typically costs between $16,000-$18,000 per year, with discounts available for multi-year agreements. Additional costs apply for QA reviews by HITRUST, which can cost as much as:

  • e1: $5,700
  • i1: $6,650
  • r2: $7,750

If you’re interested in a simplified way to start your HITRUST assessment process, check out our HITRUST Preparedness Calculator. It’s one of the best ways to see where you’re at, what assessment type you need, and what to do next.

SecurityMetrics can help you select the best certification and approach for your organization. 

What are the typical milestones of a HITRUST readiness assessment?

A HITRUST readiness assessment includes several milestones, such as: 

1. Scoping:

  • The first step is defining the scope of the assessment. This involves creating a scoping call to establish which domains and controls apply to their business.
  • You'll need a MyCSF subscription for this process, which is where you’ll manage the assessment.

2. Technology and Documentation Preparation:

  • Start by addressing technical requirements (such as systems, firewalls, and controls) due in the required 90-day incubation period for technology.
  • Simultaneously, review and start gathering evidence for your policies and procedures.

3. Evidence Gathering:

  • Begin collecting evidence for both the technology and policy aspects of the assessment.

4. Timeline Estimation:

  • Estimate a readiness timeline for gathering all required information and documentation. Once everything is in place, you’ll be ready to set a validation date.

5. Validation Setup:

  • Define a validation date in the MyCSF portal.
  • Schedule a QA slot with HITRUST to ensure everything is in order before submission to SecurityMetrics for validation.

6. Validation and QA Review:

  • After submitting the documentation and evidence, it can take several weeks for HITRUST to perform a QA review, depending on their workload and any follow-up questions regarding evidence.

7. Remote Validation:

  • HITRUST validation can be completed remotely, although some clients request on-site work (which is rare).

This structured approach helps ensure that the readiness assessment is comprehensive and on track for a successful HITRUST certification.

How do I know which HITRUST controls apply to my organization?

After analyzing your data, assets, and network flow, you’ll identify which of the 19 domains and their associated controls apply to your environment. Typically, this results in around 270 controls in the r2 assessment type. Documenting this information is crucial as you present it to a HITRUST Validation Assessor, like SecurityMetrics.

If part of your environment is hosted in the cloud, a key advantage is that you can inherit some controls from the environment you use, such as AWS, Azure, or other cloud-based tools that have already undergone HITRUST certification. This inheritance can significantly reduce your burden.

In order to determine your scope and apply the correct controls, you’ll need to understand your data flow, identify the systems it interacts with, and document everything. During the readiness preparation, new areas may be discovered that need to be added to the scope.

How do I define my scope for HITRUST?

Defining your scope is critical when trying to get HITRUST certification. It’s essential to narrow down your focus and determine what you can realistically manage. 

Identify which services or systems fall within the scope, then analyze what specific aspects of those services need to be included.

Given the potentially high cost and lengthy process, especially for large organizations, it’s vital to manage your scope carefully to avoid overwhelming yourself. You’ll need to consider various risk-based questions, such as:

  • How many records are you processing?
  • Is your system Internet-connected?
  • Do you have Wi-Fi?
  • What type of exposure do you face?
  • Who is using the infrastructure?
  • Are you operating in the cloud?

With the r2 assessment type, the more affirmative answers, the more controls you’ll need to address to mitigate risks. Generally, it’s advisable to start simple and gradually expand your scope.

How do I prepare for a HITRUST assessment?

Step One: Preparation

Preparing for a HITRUST assessment can require significant time and effort, especially if you're managing it alone, potentially demanding several hours of work per week. 

Many organizations find it challenging to balance this with their daily operations, which is why SecurityMetrics partners with Privaxi to offer you comprehensive support. 

Privaxi acts as an extension of your team, managing the entire process from gap analysis to evidence gathering. They break down the HITRUST domains, cross-reference existing frameworks like PCI or ISO 27001, and assist with technical configurations for platforms like AWS and Azure. They also help develop and tailor policies and procedures to your organization’s needs. 

By leveraging their expertise, organizations can focus on daily operations while ensuring readiness for validation with less strain on internal resources.

Step Two: Assessment

Once all information and evidence are uploaded, and self-assessment is complete, the assessor will review everything before submitting it to HITRUST.

It’s important to note that any new systems or processes must be in place for 90 days (60 days for policies and procedures) before they’re considered compliant by HITRUST. This is a crucial detail, as prematurely submitting a new implementation could lead to rejection.

The process includes a thorough documentation review, and if any issues arise, HITRUST may request revisions. Once everything is satisfactory, a draft report is submitted for client approval. If approved, HITRUST issues the official certification report.

  • For r2 assessments, certification is valid for two years, provided you maintain your processes during an interim assessment in the second year.
  • For i1 assessments, certification is valid for two years, provided you maintain your processes during a sampling assessment in the second year, called the “Rapid Recertification.”

How long does a certification take?

The timeline for certification depends on the assessment type and your organization’s complexity:

  • e1 assessment: Typically 3–4 months.
  • i1 assessment: Usually 6–8 months.
  • r2 assessment: Varies widely, based on complexity. Smaller organizations may achieve certification in 10–12 months, while larger or more complex environments can take up to two years.

Internal deadlines and the organizational environment will play a significant role in determining the most suitable approach.

How do I prioritize HITRUST tasks? What should I do first? 

Start by addressing the technology requirements since HITRUST mandates a 90-day incubation period for technologies to be operational before they can be validated. For example, you can't install a firewall and submit it as evidence the next day—it must be in place for at least 90 days.

Next, focus on policies and procedures, which require a 60-day incubation period. By tackling these early, you ensure they meet the timeframe requirements while freeing up time to work on other framework areas. 

Using a predefined list of requirements can help streamline this process and keep you ahead of deadlines.

How do I use the MyCSF Portal?

The MyCSF portal is where you’ll engage in the HITRUST validation assessment. When you’re serious about this process, you’ll need to subscribe and schedule an assessment with the HITRUST Alliance. However, you can review your controls with an assessor before making any commitments.

If you’re new to this process, SecurityMetrics can guide you through the initial steps before you decide on your scope or the type of assessment you need. 

Ultimately, you’ll need to purchase access to HITRUST’s MyCSF Portal and work with experts on the readiness side to ensure all necessary policies and procedures are implemented.

HITRUST uses a five-level maturity model:

  1. Policy
  2. Procedure
  3. Implementation
  4. Measurement
  5. Management

You must provide evidence in the portal that you’re fulfilling the required controls. Organizations must also score themselves on how well they meet these controls, with guidance available from HITRUST documentation. 

Once self-assessment is complete, your assessor (such as SecurityMetrics) will review and validate the information before final submission.

How can I improve my HITRUST certification process?

After identifying your controls, the preparation phase begins, focusing on readiness and remediation. During this phase, you’ll break down each domain, assess your current status, leverage existing work, and conduct a gap analysis to identify and address any deficiencies.

Privaxi and SecurityMetrics work together with security engineers and compliance teams to identify gaps and integrate necessary changes throughout the program’s lifecycle.

With the added service of HITRUST readiness and remediation, provided by Privaxi, the work inside the MyCSF portal can largely be carried out by Privaxi, sparing you from many of the tasks you would normally have to shoulder yourself. For example, Privaxi can help with evidence collection, evidence scoring, and policy and procedure writing, as well as many other tasks for HITRUST certification preparation..

As we manage all aspects of HITRUST—from scoping to validation, SecurityMetrics and Privaxi help secure your business while maintaining real-time visibility into your operations. Our expertise in AWS, Azure, Google Cloud, and on-premises solutions allows us to tailor strategies that meet your compliance needs and prepare your company for future challenges.

Additionally, throughout the process, collaboration tools like Asana, Microsoft Teams, Slack, and OneDrive are used to ensure smooth collaboration and communication between teams.

Is there flexibility to jump from a low-level of assurance assessment (e1) to a high-level assessment? 

Yes, there is flexibility, so you don't have to feel like you're locked into any one particular standard. 

You can start with an e1 and transition to an i1 or r2 in subsequent years. The process is fluid, so you're not locked into one standard. Additionally, both the i1 and r2 operate on two-year cycles, with the second year involving a reduced scope assessment, which lowers costs and effort.

Can the HITRUST certification help me get other certifications?

Yes, HITRUST certification makes it easy to jump on the path to other certifications, such as:

  1. NIST 800-53: If you've completed the HITRUST r2 assessment, the work you've already done for HITRUST will make the NIST 800-53 certification much easier to achieve. The controls and frameworks overlap, meaning much of the heavy lifting is already done in the HITRUST process.
  2. ISO 27001: Similarly, once you have HITRUST r2, ISO 27001 certification becomes a more achievable goal. The alignment of controls within HITRUST provides a strong foundation for meeting the ISO requirements.
  3. SOC 2: There’s also a significant amount of cross-referencing between HITRUST and SOC 2 controls, especially around security and operational procedures. If you’re HITRUST-certified, transitioning into SOC 2 can be more efficient due to the overlap.
  4. PCI DSS: HITRUST also incorporates many PCI DSS controls, especially around endpoint protection and other technology-related security measures.

HITRUST's comprehensive nature and the fact that it addresses a broad range of cybersecurity, privacy, and risk management domains mean that it provides a great foundation for achieving a variety of other certifications.

How does HITRUST compare to other assessments, such as SOC, NIST, etc.? 

HITRUST integrates elements from frameworks like NIST, ISO, PCI, and HIPAA. While frameworks like NIST focus on specific controls, HITRUST covers a broader range of domains, including cybersecurity, privacy, and risk management. It also requires more thorough documentation and evidence collection—simply having policies and procedures, as in a HIPAA audit, isn't enough; HITRUST demands detailed evidence at a granular level.

HITRUST is considered by some to be the gold standard in cybersecurity because of the depth and the customization required to meet its standards. Additionally, organizations can leverage prior efforts from other assessments (like SOC or PCI) through a mapping exercise, reducing redundancy in the process.

A readiness assessment is crucial before attempting HITRUST validation. It ensures your organization is fully prepared and that the foundational work is solid, making the validation process smoother.

What’s next after I submit my assessment?

After submitting your assessment, HITRUST will review it, potentially asking for clarifications or corrections. 

Once everything is finalized, HITRUST may issue a Corrective Action Plan (CAP) report. This report may indicate a successful pass or outline areas needing improvement before final certification.

Remember, certifications require ongoing maintenance; they are not a one-time effort. You’ll need to maintain compliance with specific control elements continuously.

Hackers don’t take breaks, and time is on their side. Staying vigilant with the support of SecurityMetrics and Privaxi helps protect your organization from evolving threats.

What happens if I have staff leave during the HITRUST certification process?

When staff leave during the HITRUST preparation process, it can be a significant disruption. 

However, having HITRUST partners like Privaxi helps mitigate this issue by providing additional staffing support to ensure the project continues smoothly. Here’s how it works:

1. Staff Augmentation:

  • If key staff members leave, SecurityMetrics’ HITRUST partner, Privaxi, can step in with their team to provide the necessary expertise and resources to continue moving forward with the project.
    This means you’re not left scrambling to fill gaps with limited internal resources.

2. Full Spectrum of Support:

3. Continued Progress:

  • By leveraging external expertise, clients don't need to pause their efforts or put the project on hold. Whether it's for technical guidance, policy development, or evidence gathering, your readiness assessor partner can keep everything on track, regardless of staffing changes.

This approach ensures continuity and reduces the impact of staff turnover on the readiness and validation process.

What happens if I have significant changes after completing my HITRUST validation?

If your organization undergoes significant changes after completing a HITRUST validation (such as changes in technology, processes, or business structure), here's what you need to do:

  1. Notify HITRUST: Significant changes should be communicated to HITRUST to ensure they're aware of the modifications.
  2. Reassessment: If the changes are substantial enough, you may need to undergo a reassessment. This means evaluating the new changes in light of HITRUST's controls and ensuring they still meet the standards.
  3. Document and Submit: The changes must be documented and submitted to HITRUST for review. While you might not need to start from scratch, the changes need to be thoroughly assessed and incorporated into the certification.
  4. Involve HITRUST Early: If you're undergoing a major change like a merger or acquisition, it's critical to involve HITRUST early in the process. HITRUST will provide authoritative guidance on how to proceed and whether a full reassessment is needed.

It's important to work closely with HITRUST in such situations to avoid missteps and ensure compliance with the standards. Consulting with HITRUST directly helps clarify what specific changes will trigger reassessments or additional validation.

Conclusion

HITRUST may have you asking a lot of questions, but security and compliance aren’t optional. They are critical to your organization’s success. 

Arming yourself with the best protection and certifications will place you at a level above most other organizations. Getting HITRUST certified will allow you to proceed with confidence and peace of mind. 

If you’re having trouble getting started, SecurityMetrics’ team of experts will be your guide through HITRUST. Partnering with the right people can make all the difference. If you’d like to learn more about our HITRUST services, chat with our team today.

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