Guide to Implementing HICP

Written by
Rebecca Williams
GRC Consultant

The Health Industry Cybersecurity Practices (HICP) framework was developed by the US Department of Health and Human Services (HHS) and the Health Sector Coordinating Council (HSCC) to help healthcare organizations strengthen their cyber resilience.

Unlike rigid certification programs, HICP offers a practical, risk-based roadmap that is helping hospitals, clinics, insurers, and their vendors protect patient data and maintain trust in an increasingly digital healthcare system.

What is HICP?

HICP stands for Health Industry Cybersecurity Practices and is a voluntary framework first published by HHS in 2018 and updated in 2023. It was created in response to the Cybersecurity Act of 2015, which called for practical, scalable recommendations to reduce cyber risks in healthcare.

The framework is divided into:

  • Two audience profiles: Small organizations vs. medium/large organizations.
  • Five key cybersecurity threats most likely to impact the healthcare sector.
  • Ten recommended best practices for mitigating those risks.

Why HICP matters

Healthcare organizations have unique cybersecurity challenges: high data value, legacy systems, 24/7 operations, and limited downtime tolerance. HICP matters because it:

Aligns clinical operations and IT: Balances security with patient care continuity.

Scales by organization size: Adapts to resource and technology differences.

Bridges frameworks: Maps to NIST CSF, HIPAA Security Rule, and HITRUST CSF.

Encourages collaboration: Strengthens partnerships across providers, vendors, and regulators.

Five cybersecurity threats in HICP

The HICP framework identifies five threats as the most critical to healthcare security:

Threat 1

Email Phishing

Deceptive emails that steal credentials or deliver malware.

  • DMARC/DKIM/SPF, secure email gateways
  • User training & simulations
  • Report-phish workflow
Threat 2

Ransomware

Malware that encrypts systems and demands payment.

  • EDR, immutable backups, tested restore
  • Network segmentation / least privilege
  • IR plan with isolation steps
Threat 3

Data Loss / Exfiltration

Unauthorized transfer or exposure of PHI/ePHI.

  • DLP policies, outbound monitoring
  • Encryption in transit/at rest
  • Retention & deletion controls
Threat 4

Insider Threat

Malicious or accidental misuse of access by staff.

  • RBAC, joiner/mover/leaver automation
  • Audit logs & anomaly alerts
  • Targeted training
Threat 5

Connected Medical Devices

Vulnerabilities in networked clinical equipment.

  • Device inventory, firmware patching
  • Clinical network segmentation
  • Supplier SBOMs / advisories

10 recommended practices

HICP defines ten best practices that map directly to the above threats. Each can be scaled depending on organization size, resources, and maturity.

HICP — 10 Recommended Practices

0% complete (0 of 10)
Open practices: 10

1) Email Protection

DMARC, secure gateways, phishing simulations, report-phish workflow.

2) Endpoint Protection

EDR/AV, patch cadence, disk encryption, device hygiene dashboards.

3) Access Management

MFA, SSO, least privilege, JML automation, privileged access reviews.

4) Data Protection & DLP

Encryption at rest/in transit, DLP, retention & deletion policies.

5) Asset Management

Hardware/software inventory, auto-discovery, config baselines.

6) Network Management

Segmentation, IDS/IPS, zero-trust network access, egress controls.

7) Vulnerability Management

Scanning, prioritised remediation, CVE watchlists, patch SLAs.

8) Incident Response

IR plan, tabletop exercises, comms playbook, after-action reviews.

9) Medical Device Security

Device inventory, firmware updates, clinical network isolation.

10) Cybersecurity Policies

Governance, policy lifecycle, workforce training & attestations.

Steps to implement HICP

Implementing HICP doesn’t require a full overhaul. Start with foundational practices and gradually expand as capabilities grow.

Assess Current State

Run a gap analysis versus HICP’s 10 practices; prioritise high-risk areas.

Form a Cross-Functional Team

Include IT, clinical, operations; define escalation and decision rights.

Quick-Win Controls

Roll out MFA, phishing simulations, backups, and EDR first.

Layered Defences

Segment networks, manage devices, implement DLP and logging.

Integrate Frameworks

Map HICP to HIPAA NIST HITRUST for unified reporting and reuse.

Monitor and Improve

Automate evidence and control checks; review annually and after incidents.

Book a demo to see how Complyance can automate HIPAA, HITRUST, and HICP frameworks in one platform.

FAQs

Is HICP mandatory? No. HICP is a voluntary framework, but it aligns closely with HIPAA and NIST CSF, making it a strategic tool for compliance readiness.

How does HICP differ from HIPAA? HIPAA defines legal requirements for PHI protection; HICP offers practical guidance to meet and exceed those requirements.

Does HICP certification exist? No. HICP is not a certifiable standard but adopting its practices strengthens your position for frameworks like HITRUST CSF.

How often should HICP be reviewed? At least annually, or after significant infrastructure or threat landscape changes.

Can Complyance support HICP adoption? Yes! Complyance automates evidence gathering, maps HICP to other frameworks, and monitors controls continuously for healthcare clients.

Complyance is the AI powered, end-to-end GRC platform