Do Dental Practices Need a HIPAA Risk Assessment Every Year?

Short answer: yes, in practice. HIPAA requires every dental practice that is a covered entity to complete an accurate and thorough security risk analysis and to keep it current. The rule does not set a fixed calendar, but reviewing it at least once a year, and after any major change, is the standard OCR expects to see.

01

What the rule actually says

The HIPAA Security Rule requires a risk analysis of all electronic protected health information you create, receive, maintain or transmit, plus ongoing risk management to reduce the risks you find. It also requires periodic review of your security measures.

"Periodic" is not defined, which is why most practices and auditors treat a yearly review as the baseline.

02

When to update it sooner

  • You open or acquire a location.
  • You change practice management software, imaging systems or your IT provider.
  • You move to the cloud or add new vendors that handle patient data.
  • You have a security incident, even a small one.

After a breach, the first document OCR usually asks for is your risk analysis. An outdated one is treated much like having none.

FAQ

Frequently asked questions

Is the HIPAA risk analysis the same as a risk assessment?

People use the terms interchangeably. The Security Rule calls it a risk analysis: identifying where patient data lives, the threats to it, how likely and serious they are, and what you will do about them.

Can we do the risk assessment ourselves?

You can, and HHS offers a free Security Risk Assessment Tool. Many practices use an outside analyst because the result has to be accurate and thorough enough to stand up in an investigation.

What happens if we never did one?

Missing risk analyses are among the most common findings in OCR settlements. Start now, document it and follow it with a remediation plan.

Sources: HHS: Guidance on Risk Analysis · HHS Security Risk Assessment Tool. This page is general information as of November 2026, not legal advice.

Find out where your practice stands

Take the free HIPAA risk assessment, or have our analysts do a full one for you.