HIPAA Architecture Framework for Network Segmentation: Meeting 2025 Security Rule Requirements

New HIPAA Security Rule: Latest Information

The healthcare cybersecurity landscape is undergoing a seismic shift with the Department of Health and Human Services' (HHS) proposed update to the HIPAA Security Rule. Published on January 6, 2025, this represents the first major overhaul of these regulations in over two decades and signals a fundamental change in how healthcare organizations must approach network security.

The proposed rule transforms network segmentation from an "addressable" specification to a mandatory requirement for healthcare organizations. This shift comes in response to the alarming rise in healthcare cyberattacks, with over 167 million patient records compromised in 2023 alone. Between 2018 and 2023, the healthcare industry experienced a 260% increase in cyberattacks and a 264% increase in ransomware incidents.

While the final rule is still pending—with the comment period having closed on March 7, 2025—healthcare security leaders should begin preparing now. The administration change has created some uncertainty about timing, but the industry consensus is that enhanced security requirements are inevitable, particularly around network segmentation.

According to the HHS' Office for Civil Rights proposal, once finalized, covered entities will have 180 days to implement the new controls. The proposed update has received significant attention from industry associations like CHIME, the American Hospital Association, and others who have expressed concerns about implementation costs (estimated at approximately $9.3 billion in the first year) and timelines.

New Cybersecurity Requirements

The proposed HIPAA Security Rule update introduces several stringent cybersecurity requirements that directly impact how healthcare organizations must architect their networks. Key among these is mandatory network segmentation under section 45 CFR 164.312(a)(2)(vi), which requires organizations to "implement technical controls to segment their electronic information systems in a reasonable and appropriate manner."

Other critical requirements include:

1. Development of a technology asset inventory and network map illustrating the movement of electronic protected health information (ePHI) throughout the organization's systems
2. Implementation of 72-hour system restoration capabilities following security incidents
3. Mandatory vulnerability scanning (every 6 months) and penetration testing (annually)
4. Enhanced risk analysis and management specifications
5. Verification of business associate security measures at least annually

These requirements fundamentally alter how healthcare organizations must approach cybersecurity, requiring a strategic shift from compliance-focused to risk-based security programs. Traditional approaches using VLANs and static firewall rules will no longer suffice—organizations must implement dynamic, identity-based controls that adapt to modern healthcare environments.

Network Segmentation Overview

Network segmentation has long been recognized as an effective security control, but its implementation has evolved significantly. Legacy approaches relied on physical network divisions using VLANs, subnets, and hardware firewalls, with security rules tied to IP addresses and ports rather than workload identities.

The problem with traditional segmentation is that it creates rigid, static boundaries ill-suited for today's dynamic healthcare environments. Modern healthcare networks must support a complex ecosystem of clinical applications, IoT medical devices, remote access, and cloud services—all while protecting sensitive patient data.

Modern network segmentation implements the zero trust principle of "never trust, always verify" by creating security boundaries based on identity rather than network location. This approach provides granular control over communication between users, devices, and applications regardless of their physical or virtual location.

According to Forrester Wave™, Microsegmentation Solutions, Q3 2024, organizations that implement modern microsegmentation typically reduce vulnerable attack paths by 70-90% compared to traditional segmentation approaches.

Greenfield - Best Practice Network Architecture for New Environments

For healthcare organizations building new environments, implementing a modern network architecture based on identity-driven microsegmentation provides the strongest foundation for HIPAA compliance and cybersecurity.

The ideal architecture follows a comprehensive people-process-technology framework:

People: Establish clear roles and responsibilities for security and network teams with specialized training on zero trust principles. Create a cross-functional security governance team that includes clinical stakeholders to ensure security controls support patient care workflows.

Process: Implement policy-based security workflows that start with asset discovery and classification. Document data flows for all ePHI systems and establish continuous monitoring processes. Develop simulation capabilities to test policy changes before implementation, ensuring patient care is never disrupted.

Technology: Deploy identity-based microsegmentation that creates security boundaries based on the identity and context of users, devices, and applications. The foundation of this architecture is comprehensive visibility—you can't secure what you can't see.

For new environments, Elisity's approach enables healthcare organizations to rapidly implement a modern security posture by applying microsegmentation across all users, workloads, and devices. The platform is designed to be implemented in week, without downtime, rapidly discovering every user, workload, and device on an enterprise network and then correlating comprehensive usage insights into the Elisity IdentityGraph™.

This empowers security teams with the context needed to automate classification and apply dynamic security policies to any device wherever it appears on the network. These granular, identity-based microsegmentation security policies are managed in the cloud and enforced using existing network switching infrastructure in real-time, even on ephemeral IT/IoT/OT devices.

Brownfield - Meeting 2025 HIPAA Security Rule Requirements in Existing Environments

For established healthcare environments, transitioning to the new HIPAA Security Rule requirements presents unique challenges. Legacy systems, medical devices with limited security capabilities, and complex clinical workflows make network redesigns particularly risky.

The practical approach for brownfield environments includes:

People: Create a small dedicated microsegmentation implementation team with representatives from security, networking, and clinical operations. Establish clear communication channels with stakeholders to ensure changes don't disrupt patient care.

Process: Begin with comprehensive discovery—map your existing network architecture, document data flows, and identify critical systems. (Note: This is a key capability of Elisity.) Start with monitoring before enforcement, using an asset discovery and visibility platform in "observe mode" to understand normal traffic patterns before implementing controls.

Technology: Implement a phased approach to microsegmentation that doesn't require network redesign or downtime. Prioritize protecting critical ePHI systems, then gradually expand coverage using a risk-based approach.

Elisity's microsegmentation platform is particularly well-suited for brownfield healthcare environments because it works with existing infrastructure without requiring agents —critical for medical IoT/IoMT devices that cannot accommodate additional software. According to customers like Bupa Cromwell Hospital, deployment can happen without disrupting critical services, providing immediate security benefits while maintaining patient care continuity.

As CISO Paul Haywood noted, "In my 30 years of working in technology and security, I've never delivered a product into an environment and got instant benefit like we did with Elisity and Claroty's Medigate."

Legacy vs. Modern Microsegmentation Approaches

Zero Trust Microsegmentation: A Strategic Imperative for Healthcare

As healthcare organizations prepare for the 2025 HIPAA Security Rule requirements, implementing zero trust microsegmentation has become a strategic imperative rather than just a compliance checkbox. The rise in sophisticated attacks targeting healthcare, combined with the expanding attack surface of connected medical devices, demands a new approach to network security.

Modern microsegmentation provides healthcare organizations with the ability to contain breaches, prevent lateral movement, and protect sensitive patient data without disrupting critical care operations. By moving from traditional network segmentation to identity-based microsegmentation, healthcare security leaders can achieve both stronger security and operational efficiency.

Elisity's approach represents a leap forward in network segmentation architecture, enabling healthcare organizations to implement comprehensive microsegmentation without the complexity and disruption of legacy approaches. By leveraging existing infrastructure and providing the visibility and context needed to make informed security decisions, Elisity helps healthcare organizations meet new HIPAA requirements while improving their overall security posture.

As healthcare cybersecurity challenges continue to evolve, implementing zero trust microsegmentation isn't just about compliance—it's about protecting patient data, ensuring service availability, and maintaining trust in our healthcare institutions. The time to begin this transformation is now, before the final rule comes into effect and certainly before the next major security incident affects your organization.

To gain a clearer understanding of how Elisity's identity-based microsegmentation can help your healthcare organization meet the 2025 HIPAA Security Rule requirements while protecting critical patient systems, schedule a consultation with one of our healthcare cybersecurity experts who can assess your specific environment and demonstrate how to implement microsegmentation without disrupting clinical operations—contact us today for a personalized conversation and implementation roadmap.