Is encryption required under HIPAA?

The correct response is that encryption is an addressable implementation specification under HIPAA. This means that while the HIPAA Security Rule recognizes encryption as a method for protecting ePHI (electronic Protected Health Information), it does not mandate its use in all instances. Instead, covered entities and business associates are required to assess their specific circumstances and determine whether encryption is a reasonable and appropriate safeguard for their specific environment.

If the decision is made not to implement encryption, the entity must document the rationale for this choice and must implement an equivalent alternative safeguard if it is deemed necessary for the protection of ePHI. This flexibility allows organizations to tailor their compliance strategies based on their size, capabilities, and risk assessments, rather than being beholden to a one-size-fits-all requirement for encryption.