“We’re Getting SOC 2 Type 2 … So Why Do We Need HIPAA?”
For many organizations, achieving SOC 2 Type 2 is a major milestone. It signals that your controls are not only well designed, but that they operate effectively over time. It builds trust with customers, strengthens your position in the market, and often becomes a key asset in sales conversations.
So when HIPAA (Health Insurance Portability and Accountability Act) enters the picture, the reaction is often hesitation:
“Doesn’t SOC 2 already cover that?”
It’s a reasonable assumption, but it’s also where many organizations unknowingly create risk.
The Overlap That Causes Confusion
SOC 2 is intentionally broad. It evaluates your organization against the Trust Services Criteria, focusing on how you manage security, availability, confidentiality, and privacy. Because of that flexibility, many of the controls you implement, like access management, monitoring, and incident response, look very similar to what HIPAA requires.
On the surface, it can feel like you’ve already done the work.
But the key difference lies in intent. SOC 2 is designed to demonstrate that your controls are well designed and operating effectively over time. HIPAA, by contrast, is legislation that defines how Protected Health Information (PHI) must be handled under U.S. Law. It is not a certification. Compliance is demonstrated through how well organizations implement and maintain the required safeguards.
That distinction matters more than most organizations expect.
HIPAA also introduces a distinction that SOC 2 does not: who you are in relation to the data. Under HIPAA, Covered Entities include organizations such as healthcare providers, insurers, and clearinghouses that directly handle patient care and billing. Business Associates are third parties that process, store, or transmit Protected Health Information (PHI) on behalf of those entities, such as cloud providers, SaaS platforms, and managed service providers.
This distinction defines the legal obligations your organization must meet. Even if you never interact with patients directly, handling PHI as a Business Associate still brings you into scope under HIPAA, along with requirements like Business Associate Agreements (BAAs) and defined safeguard responsibilities. SOC 2 does not distinguish between these roles; HIPAA does, and that distinction shapes how compliance is applied in practice.
Where SOC 2 Leaves a Gap
A SOC 2 report tells your customers that your systems and processes are operating as described. What it doesn’t do is confirm that those systems meet specific regulatory requirements for healthcare data.
HIPAA introduces obligations that go beyond general security best practices. It defines how Protected Health information, PHI, must be used, who can access it, how it should be disclosed, and what must happen in the event of a breach. It also requires formal agreements, like Business Associate Agreements, and establishes clear expectations around breach notification and patient rights. These are not areas SOC 2 is designed to fully address.
HIPAA is also structured into multiple rules, most notably:
Privacy Rule: Governs the use and disclosure of PHI and establishes individual rights over health information.
Security Rule: Focuses on administrative, physical, and technical safeguards to protect electronic Protected Health Information (ePHI).
So while your SOC 2 report may be strong, it doesn’t answer a critical question for healthcare clients: Are you compliant with HIPAA?
When This Becomes a Real Problem
This gap usually shows up at the worst possible time, when you’re trying to close a deal or expand into the healthcare space.
A prospective client reviews your SOC 2 report and is impressed. But then the conversation shifts. They ask whether you can sign a Business Associate Agreement, how you manage PHI under HIPAA rules, or whether you’ve completed a formal HIPAA risk assessment.
If your program hasn’t been built with HIPAA in mind, those questions can slow things down quickly. In some cases, they can stop the conversation altogether. It’s not because your controls are weak, it’s because they’re not aligned to the framework your client is required to follow.
The Advantage You Already Have
The good news is that if you’ve achieved SOC 2, you’re much closer to HIPAA compliance than you might think.
Most of the foundational elements are already in place. Your organization likely has structured access controls, a defined approach to risk management, documented incident response procedures, and visibility into system activity. These are all critical components of the HIPAA Security Rule.
What’s missing isn’t the foundation, it’s the layer that connects those controls directly to HIPAA’s specific requirements. That means you’re not starting over. You’re refining, extending, and aligning what you already have.
A Smarter Way to Approach It
Rather than treating HIPAA as a completely separate initiative, the more effective approach is to build on your existing SOC 2 program.
Start by identifying where protected health information exists in your environment and how it flows through your systems. From there, a HIPAA-focused risk assessment helps identify any gaps that are specific to PHI.
The work that follows is often about adding clarity and specificity, ensuring policies address HIPAA expectations, formalizing required agreements, and confirming that your processes align with regulatory requirements, not just best practices.
When approached this way, HIPAA becomes an extension of your existing program, not a duplicate effort.
The Bigger Picture
SOC 2 and HIPAA serve different purposes, but together they tell a much stronger story. SOC 2 demonstrates that your controls are effective and consistently followed. HIPAA shows that those controls meet the legal and regulatory expectations tied to healthcare data.
One builds trust. The other enforces compliance.
For organizations operating in or entering the healthcare space, that combination is often what turns a strong security posture into a true competitive advantage.
Final Thoughts
It’s easy to assume that SOC 2 Type 2 is enough, especially given how comprehensive it feels. But when protected health information is involved, the expectations change.
HIPAA isn’t a certification. It’s a legal framework that sits alongside everything you’ve already built. The organizations that recognize this early, and align both efforts strategically, are the ones that avoid delays, reduce risk, and move more confidently in a highly regulated market.
How MHM Can Help
At MHM, we work with organizations that have already achieved SOC 2 Type 2 and need to take the next step into HIPAA. By building on your existing controls and aligning them to HIPAA requirements, we help you close gaps without duplicating effort, so you can meet client expectations and move forward with confidence.
