A Practical Guide to Privacy, Security, and Role-Based Accountability with ezRACI.
For any organization that stores, processes, or transmits protected health information (PHI), HIPAA compliance isn’t just a regulatory box to check—it’s a legal and ethical mandate.
But while many healthcare organizations and their vendors know the “what” of HIPAA, they often struggle with the “who.” Who’s responsible for what tasks? Who needs to be consulted before decisions are made? Who needs to be informed?
That’s where the RACI matrix comes in.
This 10-chapter guide walks you through the full HIPAA compliance journey—privacy, security, training, breach response, and beyond—and shows how a RACI matrix, powered by ezRACI, helps you achieve and sustain compliance with clarity and coordination.
The Health Insurance Portability and Accountability Act (HIPAA), enacted in 1996, is a U.S. law designed to protect the privacy and security of sensitive health information. It applies to:
Covered Entities – Healthcare providers, plans, and clearinghouses
Business Associates – Vendors and service providers who handle PHI on behalf of covered entities
Subcontractors – Any third-party processors with access to PHI
HIPAA consists of several key rules:
Privacy Rule – Governs how PHI can be used or disclosed
Security Rule – Sets standards for securing electronic PHI (ePHI)
Breach Notification Rule – Requires notification of affected individuals and regulators in case of a data breach
Omnibus Rule – Expands responsibilities for business associates
HIPAA noncompliance can lead to fines up to $1.5 million per year, civil lawsuits, and reputational damage. The good news? A strong internal compliance program—with well-defined roles—can significantly reduce your risk.
The RACI model—Responsible, Accountable, Consulted, Informed—helps organizations eliminate confusion over “who does what” across complex initiatives. In the context of HIPAA, RACI brings structure to critical compliance activities like:
Performing risk assessments
Implementing access controls
Managing training programs
Monitoring third-party vendors
Handling breach notifications
Updating policies and procedures
Without RACI, many organizations fall into one of two traps:
No ownership at all—tasks fall through the cracks
Too much ownership—the CISO or Privacy Officer becomes a bottleneck
By applying a RACI matrix across HIPAA’s requirements, teams get clear direction, and leadership gets full visibility.
The HIPAA Privacy Rule governs how PHI is used and disclosed, and ensures patients have rights over their information. Key compliance requirements include:
Disclosures of PHI
Minimum necessary standard
Notice of privacy practices
Patient access and amendments
Authorization procedures
Example RACI mapping:
Task | Responsible | Accountable | Consulted | Informed |
---|---|---|---|---|
Draft and distribute NPP | Compliance Officer | Privacy Officer | Legal | HR |
Handle access requests | Records Clerk | Privacy Officer | IT | Patient |
Review use of PHI in marketing | Marketing Manager | Legal Counsel | Privacy Officer | Exec Team |
With ezRACI, organizations can plug these tasks into a prebuilt template and assign clear roles across legal, HR, IT, and compliance.
The Security Rule governs how ePHI must be protected through administrative, technical, and physical safeguards.
Key activities include:
Risk analysis and management
Workforce security
Access control
Audit controls
Incident response procedures
RACI helps teams track technical vs administrative responsibilities. For example:
Task | Responsible | Accountable | Consulted | Informed |
---|---|---|---|---|
Perform annual risk assessment | Security Analyst | CISO | Compliance | Legal |
Configure access controls | IT Admin | IT Director | Security Architect | HR |
Set up audit logs | DevOps | CTO | Privacy Officer | GRC |
ezRACI allows these controls to be managed as tasks, tied to team members, and monitored through live dashboards.
HIPAA requires all workforce members to be trained on privacy and security policies. But training often gets deprioritized—or becomes a once-a-year checkbox.
A RACI approach makes it operational:
Task | Responsible | Accountable | Consulted | Informed |
---|---|---|---|---|
Develop training materials | HR & Compliance | People Ops | Legal | All Employees |
Track completion | HR Systems Admin | HR Director | Team Leads | Compliance Officer |
Respond to policy-related questions | HR Partner | Compliance Lead | Legal | Department Heads |
With ezRACI, these recurring tasks can be automated and assigned annually, quarterly, or on-demand.
Every business associate that handles PHI must be vetted and governed. This includes cloud providers, billing services, IT vendors, and subcontractors.
HIPAA requires:
Signed Business Associate Agreements (BAAs)
Due diligence and security assessments
Ongoing monitoring of compliance
RACI roles might include:
Task | Responsible | Accountable | Consulted | Informed |
---|---|---|---|---|
Draft and manage BAAs | Legal | Privacy Officer | Vendor Mgmt | Security |
Perform vendor risk reviews | Compliance Analyst | GRC Lead | Security Team | CIO |
Track third-party assessments | Vendor Risk Lead | IT Risk Manager | Legal | Executive Team |
ezRACI helps track these engagements across your entire vendor portfolio—avoiding missed contracts and lapsed assessments.
When a breach occurs, time is of the essence. HIPAA requires notification to affected individuals within 60 days, and in some cases, notification to HHS and the media.
RACI roles ensure no delays in response:
Task | Responsible | Accountable | Consulted | Informed |
---|---|---|---|---|
Detect and escalate incident | SOC Analyst | Security Lead | Privacy Officer | Legal |
Assess breach impact | Security + Privacy | CISO | Legal | Exec Team |
Notify patients | Communications | Privacy Officer | Legal, HR | HHS |
ezRACI’s templates ensure these tasks are predefined and pre-assigned—so you’re ready before something happens.
HIPAA compliance is only as strong as your documentation. You must maintain:
Policies and procedures
Security risk assessments
Employee training logs
Access logs and audit trails
Incident reports
RACI helps ensure documentation is up to date, reviewed regularly, and accessible.
Task | Responsible | Accountable | Consulted | Informed |
---|---|---|---|---|
Maintain policy register | GRC Analyst | Privacy Officer | Legal | Department Leads |
Update retention policy | Records Manager | Compliance Officer | Legal, IT | HR |
Prepare audit documentation | Compliance Lead | CISO | Security, Legal | Auditors |
ezRACI provides live, role-based document tracking tied to owners and review cycles.
HIPAA is not a one-time event. To remain compliant, you must conduct:
Periodic internal audits
Control assessments
Corrective action tracking
This is where most compliance programs lose momentum—but a RACI model brings rhythm.
Task | Responsible | Accountable | Consulted | Informed |
---|---|---|---|---|
Plan internal audit schedule | GRC Manager | CISO | Privacy Officer | Exec Team |
Conduct control reviews | IT Security | Compliance | Legal | Internal Audit |
Track corrective actions | Compliance Analyst | Risk Lead | Department Heads | Auditors |
ezRACI allows you to set reminders, delegate responsibilities, and log results in a single system.
HIPAA compliance spans multiple departments—IT, HR, Legal, GRC, and beyond. A spreadsheet can’t handle that complexity. That’s why teams are turning to ezRACI.
With ezRACI, you can:
✅ Use pre-built HIPAA RACI templates
✅ Assign and track responsibilities across departments
✅ Integrate with Slack, Microsoft Teams, and Jira
✅ View task status, due dates, and evidence links
✅ Export audit-ready reports in seconds
Whether you're a healthcare provider, insurer, or a business associate handling PHI, ezRACI helps you operationalize HIPAA with clear ownership, proactive management, and scalable documentation.
👉 Get started today at www.ezraci.com