HITRUST vs SOC 2: Leveraging the best path to assurance in compliance
Service organizations can agree that providing assurances of the protection of systems and data security is the right thing to do. Some of the biggest names in healthcare organizations require their service organizations, many defined as business associates under HIPAA, adopt the HITRUST CSF (i.e., become HITRUST certified). But what is HITRUST, and how does it compare to other compliance frameworks like SOC 2 when it comes to safeguarding protected health information (PHI)?
Defining HITRUST and SOC 2 in the context of compliance
HITRUST, which stands for Health Information Trust Alliance, is a comprehensive cybersecurity framework for managing information security and privacy risks. Understanding the HITRUST meaning is crucial for organizations dealing with sensitive healthcare data. Becoming HITRUST certified can certainly be a potential differentiator. But many service organizations who’ve undergone a SOC 2 examination wonder whether that isn’t already enough to provide the assurances healthcare organizations are requesting in terms of regulatory compliance.
Understanding the differences between HITRUST vs. Soc 2
The reason it’s not enough lies in the big difference between the two services. SOC 2 is a reporting framework, while the HITRUST CSF is a control framework, both aimed at enhancing information security and risk management practices.
SOC 2 reports, developed by the American Institute of Certified Public Accountants (AICPA), are intended to meet the needs of a broad range of users who need information and assurance about the controls at a service organization. These controls help maintain security, confidentiality, privacy, availability and processing integrity — the five trust services criteria (TSC) categories. Organizations choose which of the five TSC categories to report on and engage an independent service auditor to determine whether controls are properly designed and operating effectively.
In contrast, the HITRUST CSF is a prescriptive control framework that incorporates various compliance standards, including HIPAA compliance requirements. Although the service organization/business associate may define the scope of the environment to be tested, HITRUST controls must be in place and applied to that entire covered environment. This makes HITRUST certification a rigorous process that addresses comprehensive security controls and data privacy measures across multiple HITRUST domains.
How HITRUST and SOC 2 are similar in compliance efforts
The good news is that there are synergies between SOC 2 TSC categories and the underlying criteria and HITRUST CSF controls. By leveraging controls for addressing the HITRUST CSF requirements in SOC 2 engagements, service organizations can realize time efficiencies and cost savings. In fact, HITRUST and AICPA have collaborated to develop and publish a set of recommendations to streamline and simplify that process, enhancing overall security assurance and regulatory compliance.
Choosing between HITRUST and SOC 2 for data security
Altogether, service organizations are faced with four reporting options offered by HITRUST and the AICPA, all with cost ramifications and time implications. Choosing the right one takes careful consideration of your organization’s specific needs and regulatory compliance requirements.
Evaluating SOC 1 and SOC 2 reporting options
| Reporting options | Does this meet HITRUST requirements? | ||
|---|---|---|---|
| HITRUST CSF certification | Organizations can disregard SOC 2 and instead obtain a HITRUST CSF certification report through an assessment performed by a HITRUST-approved CSF assessor and issuance of the certification report by HITRUST. | Yes | |
| SOC 2 only | Organizations might have adopted the HITRUST CSF framework but not requested their service auditor to express an opinion on whether the controls at the service organization are suitably designed and operating effectively to meet HITRUST CSF requirements. | No | Reference to the HITRUST CSF can be included in Section 5 of the SOC 2 report, but the HITRUST CSF remains unaudited. However, for some service organizations that are depending on the relationship and the shared information, simply making a HITRUST mapping and assertion in that section of the SOC 2 report may suffice for their healthcare clients. |
| SOC 2 and HITRUST CSF | Organizations can implement controls addressing HITRUST requirements covering the TSC categories relevant to security, availability and confidentiality. A service auditor’s report then expresses an opinion on the suitability of design and operating effectiveness of those controls relevant to both SOC 2 and HITRUST CSF. | Maybe | Service organizations do not receive HITRUST CSF certification in this scenario; therefore, it is recommended that they first discuss the option with their healthcare organization clients. |
| SOC 2, HITRUST CSF and CSF certification | Organizations that have engaged a service auditor to express a SOC 2 and HITRUST CSF opinion and have achieved HITRUST CSF certification can obtain one combined report. | Yes | This scenario requires third-party assurance performed by an AICPA member firm that is also a HITRUST-approved CSF assessor. |
Choosing a HITRUST CSF-authorized assessor for the assessment process
Talking with your clients and conferring with a firm that is both an AICPA member and an approved HITRUST CSF assessor can give you the confidence you need to choose the right path to assurance. This approach ensures you select a compliance framework that makes the most sense for your business and its bottom line while meeting the necessary data confidentiality and privacy controls standards.
Wipfli is proud to be a HITRUST-authorized CSF assessor. As a CPA firm with professionals who’ve served as former IT leaders in healthcare environments, we bring best practices to help organizations make their best decisions. Contact us to learn more about how we can assist with your HITRUST certification or SOC 2 attestation needs, ensuring you meet the highest standards of information protection and data security in today’s complex regulatory landscape.
By leveraging either HITRUST or SOC 2, or a combination of both, organizations can demonstrate their commitment to robust cybersecurity practices, effective risk assessment and compliance with industry standards. This not only enhances their reputation but also provides assurance to clients and partners about the security of their sensitive information in an era where data breaches are increasingly common.
