Expert Guidance for Successful HITRUST Compliance

HITRUST provides a unified framework that integrates security, privacy, and compliance into a single certifiable standard. It helps organisations, especially in healthcare, manage risks, safeguard sensitive information, and demonstrate strong, trustworthy security practices. Achieving HITRUST certification enhances credibility, reduces risk, and strengthens client confidence while simplifying compliance with multiple regulations.

Coral eSecure brings 22 years of healthcare security expertise, offering proven methodologies, faster compliance, and tailored, audit-ready implementations that help organisations avoid costly mistakes and build resilient security programs.

Questions or clarifications on HITRUST on scope, implementation, list of controls and audit? Kindly contact us for a no-obligation discussion.

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HITRUST Consulting Engagement Phases

Here is a brief overview of al the phases involves in implementing HITRUST certification.

Phase I - Scoping

Scoping involves the identification of:

Business entities
Identification of epHI and its flow including lifecycle
Information systems in scope
Business locations
Data Center and Cloud Services Providers
Users

Phase II - Gap Analysis and Risk Assessment

Based on the outcome of phase I, a combination of approaches is applied by Coral HITRUST consultants to conduct the gap analysis.

A session with each organization team to asses their current scope of work and their controls
Determination of applicable, not applicable and inherited controls, the latter applies when a cloud service provider is involved.
A status of each control requirement in red, orange and green - determining their current status.

Coral consultants will provide detailed recommendations for each identified gap with their recommendations.

Phase III - Control - Design, Documentation, Implementation, Measurement, and Risk Management

Based on the gaps and maturity status from phase II, the implementation journey begins:

Implementation journey takes the longest period of time depending on the gaps
Implementation involves discussing each gap with the team and advising changes in the short and long-term
Writing policies and procedures - that align with each applicable requirement

Phase IV - Training & Brainstorming Sessions

Training of staff involved in HITRUST operations is a key factor in successful HITRUST implementation.
Coral consultants will deliver a combination of training including awareness, risk management and standard interpretation.
Each policy documentation or risk undergoes brainstorming with staff to derive at a ‘best-fit’ solution for the organization.

Phase V - Measurement of Controls including Internal Audit

Upon the completion of the implementation phase, Coral performs monthly tests of controls to ensure that designed controls are operating effectively.

These tests are conducted across all applicable 19 domains of HITRUST.
A formal report is published for the management team for the overall program effectiveness, especially the newly developed and implemented security controls and practices.

Summary

At this stage:

As a result of undergoing these phases, Coral has successfully implemented a HITRUST governance program that includes people, processes, technology and ongoing measurements.
Each of the HITRUST certification requirements has been completed by a combination of one or more of policy, procedures, responsibilities, reports, records, technology, and automation.
At this stage, the organization is ready to initiate the external HITRUST assessment.

Phase VI - HITRUST External Assessment support

We facilitate the external HITRUST assessment by providing all the support clients need to achieve successful compliance.

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What are 19 Domains of HITRUST^®?

Information Protection Program
Endpoint Protection
Portable Media Security
Mobile Device Security
Wireless Security
Configuration Management
Vulnerability Management
Network Protection
Transmission Protection
Password Management
Access Control
Audit Logging and Monitoring
Education, Training, and Awareness
Third-Party Assurance
Incident Management
Business Continuity and Disaster Recovery
Risk Management
Physical and Environmental Security
Data Protection and Privacy

What is HITRUST^® Maturity?

With Hitrust you receive a score of 0-100% based on how well you have demonstrated alignment with the 5 points, namely:
Policy, Procedure, Implemented, Measured, and Managed

Policy – this is achieved when you have a documented policy in line with HITRUST^®individual control requirement
Procedure – This is when you describe how you achieve the policy objectives. This involves documenting people, processes and technology references. This is also the place where you describe - who, what, how - associated with each control.
Procedure – This is when you describe how you achieve the policy objectives. This involves documenting people, process and technology references.
Measured – This is when you ‘quantitatively’ demonstrate the effectiveness of a control in place. This can be a minimum period of say 3 months, which provides a reasonable assurance of control measurement.
Managed – This is when you show how to identify risks, deviations, and opportunities for improvements, and show evidence of successful closure.

Coral consultants will assist you in defining and implementing all 5 points resulting in the client achieving optimal score for each control.

HITRUST^® Consulting FAQs

What is the role of a HITRUST consultant?
HITRUST has 19 domains. E1 has 44 controls, i2 has 182 controls, and r2 has 250+ controls. If you are new to the HITRUST certification process, hiring a HITRUST consultant can provide several benefits, such as saving time, and improving security

Here's why you might need one:
- Knowledge, Expertise and Experience in HITRUST
  The HITRUST Common Security Framework (CSF) is a comprehensive and complex framework that integrates various compliance requirements (HIPAA, GDPR, NIST, etc.). A consultant helps navigate these intricacies efficiently.
- Scoping the environment
  Scoping the engagement in terms of systems, locations, functions, service providers is a key aspect of starting the HITRUST journey. A Hitrust consultant can bring their expertise to define the scope appropriately.
- Gap Assessment
  A HITRUST consultant can perform a gap analysis to identify where your current practices fall short of HITRUST requirements, providing a clear roadmap to compliance. A gap analysis will result in determining the ‘applicable’ and ‘not applicable; requirements with suitable justifications.
- Implementation of Policies and Procedures
  A HITRUST consultant will design, and define all policies and procedures as per applicable controls. For each of the 19 domains, there is a need to define policies and procedures.
- Implementation of Secure Practices
  A HITRUST consultant will ensure policies turn into actual practices. This is through handholding teams to ensure they indeed follow these practices.
- Implementation of Secure Configurations
  Depending upon your infrastructure (cloud or on-prem or a hybrid of both) the hitrust consultant will ensure that all configurations are optimized for security.
- Risk Management Advisory
  A gap assessment will several issues or vulnerabilities, and a HITRUST consultant will provide specific advice to reduce the risk.
- Third-Party Risk Assessment
  A Hitrust consultant can evaluate the risks associated to suppliers, and provide actionable insights and recommendations.
- Penetration Testing
  A HITRUST consultant can perform testing of your Infrastructure and provide recommendations to reduce the risk.
- Training and Awareness
  HITRUST Consultants often provide training to your staff, ensuring your team understands HITRUST requirements and can maintain compliance in the future.
- Continuous Monitoring
  After the implementation process is complete, the HITRUST Consultants can assist in managing and monitoring the governance process as well as reporting the degree of effectiveness.
- Managing HITRUST external assessor expectations
  After the implementation process is complete, the HITRUST Consultants can assist in managing and monitoring the governance process as well as reporting the degree of effectiveness.
- Managing MyCSF
  After the implementation process is complete, the HITRUST Consultants can assist in managing and monitoring the governance process as well as reporting the degree of effectiveness.
- Project Management
  With several experiences in HITRUST across businesses of all size, a HITRUST consultant is fully equipped to manage your project ensuring success at the end.
In summary, engaging a HITRUST consultant is an investment in your organization's security posture, resulting in speed in achieving HITRUST certification. While you focus on your business, the HITRUST consultant can ensure success with HITRUST certification, thereby saving valuable business hours.
What is the HITRUST Implementation Process?

Before an organization applies for any of the HITRUST certifications(e1. i1 or r2), the organization has to implement the requirements. This involves conducting as-is analysis, addressing the identified gaps, policy, and procedure documentation, and a monitoring period for three months (cooling off period) before starting the HITRUST assessment
How many parties does a typical HITRUST engagement involves? What is the HITRUST Certification Process?
At least three - a HITRUST consultant, HITRUST assessor and the HITRUST itself. Unlike the ISO and SOC 2 world, the certification organization (HITRUST) is also involved.
- Phase I - Consultant involved in setting up the program, and monitoring the program for the first 3-5 months.
- Phase II - HITRUST assessor for testing and scoring the controls (audits)
- Phase III - HITRUST is responsible for provisioning MyCSF (the app) and performing Quality Assurance (QA) assessment before issuing the report
How long is the HITRUST certification good for?

e1 and i1 reports are valid for 1 year, r2 is valid for 2 years.
Who needs the HITRUST certification?

It applies to all covered entities and business associates - who wish to demonstrate a higher level of assurance to processing ePHI.
HITRUST vs. HIPAA: What’s the difference?

HIPAA is a law that aims to protect ePHI. HITRUST is an institution that was created to endorse a HIPAA-compliant organization.
Are there any penalties or consequences for failing to maintain HITRUST certification?
- The reason most organizations wish to comply with HITRUST could be seeking a third-party endorsement, as well as meeting contractual obligations.
- In case of a violation such as a breach, the penalties as per HIPAA violations apply.

Recent Case Studies

HITRUST for a SAAS platform provider in LA, CA

When Coral started the journey, the client was already SOC 2 and HIPPA compliant
The journey started by understanding the business and ePHI/PII lifecycle.
Coral consultants conducted a 3-dimensional gap analysis on the applicable controls.
The gaps came up in the architecture, tool deployments, and security processes. Coral provided recommendations for treating all the gaps.
Coral helped discuss each of the gaps and assist in defining and documenting policies and procedures.
Additionally, Coral consultants tracked every piece of evidence, resulting in the completion of all hitrust controls one by one. This involved key stakeholders including CTO, developers and the infrastructure team.
Finally, the client went through the hitrust assessment and was found to be compliant in all HITRUST requirements, resulting in successful HITRUST certification.

HITRUST for a leading actuarial and consulting firm in Seattle, WA

Coral came to the assignment as a result of the development partner who was responsible for the development of the application and maintenance in Azure.
For Coral, the engagement was to ensure the application and the underlying infrastructure using Azure reached successful HITRUST certification.

Coral HITRUST consultants were involved in the process of performing a detailed application and infrastructure gap analysis of the infrastructure as well as on all the applicable HITRUST requirements.
Coral recommended gaps were implemented by the development team and the end customers.
Coral consultants conducted a 3-dimensional gap analysis on the applicable controls.
A part of this client data center infrastructure was already certified, so Coral designed, drafted and facilitated the newly implemented policies and procedures that related to the cloud environments.
Based on Coral’s recommendations, several configuration changes were made by the client, which further improved their security posture.

In the end, Coral assisted the client in implementing all the requirements, which resulted in achieving a successful HITRUST certification.

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