HIPAA Training for Business Associates

Posted By Steve Alder on May 3, 2026

HIPAA compliance training for business associates should include Security Rule security awareness training, applicable Privacy Rule training, Breach Notification Rule procedures, and any role-specific requirements assigned through a business associate agreement. According to the Administrative Safeguards of the HIPAA Security Rule (§164.308), Business Associates must “implement a security awareness and training program for all members of the workforce (including management)”. This is the only standard in all the Administrative Simplification regulations that mentions any form of HIPAA compliance training for Business Associates.

Depending on the service being provided for or on behalf of a HIPAA Covered Entity, HIPAA Business Associates and their workforces may need to be compliant with the Administrative Requirements (particularly Part 162 Subparts I to S), and/or areas of the HIPAA Privacy Rule relating to individuals´ rights, permissible uses and disclosures, and authorizations.

HIPAA Business Associates are required to comply with the HIPAA Breach Notification Rule; and while this area of compliance may be the sole responsibility of a HIPAA Security Officer, members of a Business Associate’s workforce must be aware of the procedures for reporting incidents to supervisors, team leaders, or the Security Officer directly to ensure timely notifications to the HIPAA Covered Entity.

What Should HIPAA Compliance Training for Business Associates Consist Of?

There are multiple considerations when determining what HIPAA compliance training for Business Associates should consist of. The first is the requirements that HIPAA Business Associates must comply with the HIPAA security standards and therefore all members of a Business Associate’s workforce must take part in HIPAA security awareness training for Business Associates, even those with no access to PHI.

The reason why members of the workforce with no access to PHI must also take part in a HIPAA security and awareness training program is that cybercriminals do not know which members of the workforce have access to systems and databases in which PHI is stored. Consequently, they will target anybody within the organization in an attempt to find a way to infiltrate the network.

With regards to compliance with the Administrative Requirements, the need to provide HIPAA Business Associate training on the relevant standards of this Part will likely be stipulated in a Business Associate Agreement if the organization is providing a billing, claims management, or payment service for the Covered Entity.

Also stipulated in a Business Associate Agreement should be the areas of the HIPAA Privacy Rule organizations will be required to comply with. However, it is in every Business Associate’s best interests to ensure all members of the workforce are aware of permissible uses and disclosures and the rights of individuals to request access to information maintained in a designated record set.

Depending on the service being provided for or on behalf of a Covered Entity, HIPAA compliance training for Business Associates could consist of:

• Security and Awareness Training (required by the HIPAA Security Rule)
• Administrative Requirements HIPAA Business Associate training
• HIPAA Privacy Rule training for Business Associates
• HIPAA training for Business Associates’ breach notification rules and procedures

 

HIPAA Security Rule Training Requirements for HIPAA-Business Associates

The HIPAA Security Rule requires HIPAA business associates to provide security awareness training to all workforce members who have access to electronic information systems, including staff who do not use or disclose protected health information as part of their job duties. The relevant Security Rule provision is 45 CFR § 164.308(a)(5), Standard: Security Awareness and Training, which requires a covered entity or business associate to “implement a security awareness and training program for all members of its workforce, including management.”

For a business associate, this requirement applies to personnel with access to IT systems that create, receive, maintain, or transmit electronic protected health information. The scope is broader than role-based HIPAA training because security risks can arise from any workforce member with system access, including administrative, technical, operational, and management personnel. Security awareness training is separate from, and in addition to, HIPAA training on applicable Privacy Rule, Breach Notification Rule, and organizational policy requirements.

Benefits of Comprehensive HIPAA Training for Business Associates

HIPAA Business Associate training should be seen as more than a box-ticking exercise that mitigates the risk of a data breach and the amount of any fine imposed for non-compliance with HIPAA. It is an opportunity to teach security best practices, enhance awareness of privacy rights, and implement procedures for all types of incidents, even those that do not result in a data breach. The HIPAA Journal is the leader in HIPAA training for Business Associate staff with additional modules dedicated to HIPAA Business Associate staff on top of the standard HIPAA training.

The documentation of HIPAA training for Business Associates’ workforces not only demonstrates to HHS’ Office for Civil Rights a good faith effort to be compliant, but it can also be used to satisfy the due diligence requirements of potential business partners, potentially giving organizations that provide HIPAA Business Associate training a competitive advantage.