Delinea Blog > HIPAA MFA Requirements: What the Security Rule Asks For

HIPAA MFA Requirements: What the Security Rule Asks For

Published January 2025
Read time 5 minutes
What you will learn
HIPAA doesn't name MFA yet, but a newly proposed rule would require it. Here's what the Security Rule asks for, where MFA programs fail and how to fix them.

For healthcare providers, protecting patient data is both a legal obligation and a necessary step in establishing trust with patients and other stakeholders.

The Health Insurance Portability and Accountability Act (HIPAA) mandates safeguards for electronic protected health information (ePHI). One of the most effective ways to meet HIPAA’s security requirement is multi-factor authentication (MFA). This post covers what HIPAA asks for on authentication, common MFA challenges and how to work through them. 

Does HIPPA require MFA?

HIPAA MFA refers to using multi-factor authentication to meet HIPAA's identity verification requirement: users verify their identity with at least two different factors before accessing systems containing ePHI. The second factor protects ePHI even if one credential is compromised, and it's how most organizations satisfy the HIPAA Security Rule's authentication standard. 

HIPAA does not name MFA as a requirement today. The Security Rule requires regulated entities to verify that anyone seeking access to ePHI is who they claim to be, and MFA is the standard way to meet that. On December 27, 2024, the U.S. Department of Health and Human Services (HHS) proposed a Security Rule update that would make MFA mandatory, with limited exceptions.

The proposal is open for public comment until March 2025, and the current rule remains in effect until a final rule is published. Until then, MFA is what auditors and cyber-insurers expect rather than what the regulations spell out. 

HIPAA Security Rule overview

The HIPAA Security Rule establishes national standards to safeguard ePHI. It requires administrative, physical and technical safeguards to protect patient data. MFA satisfies the authentication standard under technical safeguards, which are designed to:

  • allow only authorized personnel to access ePHI.
  • monitor access and detect potential security breaches.
  • protect data integrity, confidentiality and availability.

MFA supports these safeguards by requiring more than one factor, so a stolen password alone doesn't grant access. 

NIST guidelines on authentication

The National Institute of Standards and Technology (NIST) provides clear guidelines on authentication, categorizing credentials into three groups:

  1. Something you know. Passwords, PINs or answers to security questions.
  2. Something you have. Physical objects like smart cards, hardware tokens or mobile devices.
  3. Something you are. Biometric data such as fingerprints or facial recognition.

To meet HIPAA's authentication standard in line with NIST guidance, organizations should implement MFA using at least two distinct categories, for example a password (knowledge) with a  one-time passcode from a smartphone (possession).


Common security vulnerabilities MFA addresses

Phishing and credential theft

Stolen credentials from phishing attacks are a leading cause of data breaches. MFA reduces this risk by requiring a second authentication factor, making compromised passwords alone insufficient.

Legacy systems and protocols

Outdated systems often lack built-in security features, leaving them vulnerable to exploitation. Where a system cannot support MFA natively, the control has to sit in front of it rather than inside it, which is the case for enforcing authentication at an access layer instead of per application. 

Password reuse and weak credentials

Password reuse is widespread, so one leaked password can open several accounts. MFA limits the damage from poor password hygiene by requiring a second factor.

Six HIPAA MFA challenges and how to solve them

1. Getting full coverage across systems

Healthcare organizations often rely on a mix of cloud-based systems, on-premise servers and legacy infrastructure. These disparate systems typically lack unified security measures, making it difficult to enforce MFA consistently across all access points. Legacy systems, in particular, may not support native MFA, leaving gaps that a cyber criminal can work through. This fragmentation creates gaps in coverage and raises the risk of unauthorized access to ePHI. 

2. Balancing security against usability

Healthcare staff, including clinicians, administrative teams and IT professionals, often face high-pressure, time-sensitive situations where efficiency is critical.

Traditional MFA solutions, which can require additional steps or complex processes for authentication, may disrupt workflows, causing frustration and resistance among users. In some cases, staff may seek workarounds, such as sharing credentials or bypassing MFA protocols, which undermines security efforts. Finding an MFA solution that balances strong security with minimal user friction is a challenge for healthcare organizations.

3. Integrating with existing identity providers

Many healthcare organizations already use identity management solutions like Active Directory (AD), Okta or LDAP to manage user authentication and access. Integrating MFA into these systems can be technically challenging, requiring customization and development effort. Incompatible systems and poor integration capabilities often lead to delays, increased complexity and errors, and MFA ends up covering less than intended.  

4. Cost and resource constraints

Implementing and maintaining an effective MFA solution can require real investment and technical expertise, both of which are often limited in healthcare organizations. IT teams are typically tasked with managing competing priorities, making it difficult to allocate time and resources for MFA implementation and ongoing support. These constraints can delay adoption and leave sensitive data exposed in the interim.

5. Audit readiness

HIPAA audits ask organizations to show how access to ePHI is controlled and reviewed, including authentication records. Many MFA tools don't log at the level of detail that takes. Without a usable audit trail, responding to an audit request is slow and the outcome is uncertain.

6. Remote access gaps

The rapid adoption of remote work in the healthcare industry has created new vulnerabilities, particularly in securing access to critical systems from external locations. Many MFA deployments don't cover remote connections consistently, leaving them exposed to phishing, credential theft and brute-force attacks. Securing remote access without slowing remote staff down is a real challenge for healthcare organizations.

How to implement MFA in four steps

  1. Perform a risk analysis. Identify vulnerabilities and map access pathways. The Security Rule requires this anyway, and it is what tells you which systems cannot support MFA natively.
  2. Deploy MFA across infrastructure. Enforce it at the access layer so the systems that can't do it themselves are still covered, and start with the paths that reach ePHI.
  3. Train employees. Keep the enrollment path short and tell people what to do when a factor fails, because that is the moment workarounds get invented.
  4. Monitor and adjust. Review authentication logs for failures and bypasses, and treat a rise in either one as a design problem, rather than a user problem.

Where Delinea helps

Most of the six challenges above come down to the same thing: MFA has to be enforced somewhere that every path to ePHI passes through, and the enforcement has to produce a record. That is what the Delinea Platform is built around. MFA can be enforced at login and again at privilege elevation through Server PAM.

Privileged Remote Access extends the same enforcement to staff and third parties connecting without a VPN, and Secret Server records the session so the authentication event and what followed it sit in the same place. That record is what makes the access decision auditable and defensible.  

For the audit side, Delinea's audit and compliance solution gathers the access evidence an an HHS Office for Civil Rights (OCR) investigation asks for, which shortens the part of an audit that usually takes the longest.

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