The 2026 HIPAA rule is a network problem.

Half of this isn't even about computers

An office manager at a three-location medical practice put it well: half of the proposed HIPAA Security Rule changes are not about computers, they are about how the offices talk to each other. For years the rule let practices treat many safeguards as addressable, a word that in practice often meant a sentence in a binder and nothing more.

The 2026 overhaul working through the Office for Civil Rights changes that posture. The direction is unmistakable: encryption of patient data at rest and in transit, multi-factor authentication on every point of access, network segmentation, vulnerability scanning, tested backups. Less consider this, more do this and be able to prove it.

Where things stand

As of this writing the updated rule is proposed, not final. A good chunk of the exact control lists circulating online come from IT-vendor blogs rather than the rule text, so treat specifics as directional until OCR publishes the final version. Once that happens, the expected compliance clock is roughly 240 days, which is not much runway for practices running more than one location.

Why this lands hardest on multi-location practices

A single-office practice has a hard enough time with this. It gets genuinely difficult for a practice that has grown to three, five, eight locations, often by acquiring smaller practices that each came with their own internet provider and their own idea of a password policy.

The rule does not care that one office runs on fiber with a real firewall while another runs on a consumer cable modem. From OCR's chair it is one covered entity, and the weakest location sets the real exposure. One unencrypted link between sites, one location without MFA, and the yes you wrote down stops being true everywhere.

Every requirement is a network decision

Almost none of these mandates are satisfied by buying a product. Encryption in transit between sites means secure, encrypted connectivity, a properly built SD-WAN or VPN backbone, not whatever the cable company handed you. Segmentation means the network is deliberately divided so a problem in the waiting room cannot reach the records room. The EHR vendor will tell you their product is HIPAA compliant, and that is fine, but the rule applies to your whole environment, not just one application.

One network, three masters

The HIPAA direction, your cyber-insurance renewal, and plain common sense are converging on the same short list: MFA everywhere, EDR on every endpoint, tested backups, encryption, segmentation, and a real inventory behind it. The smart move is to build one defensible network across all your locations, then point every requirement at it, instead of chasing each questionnaire separately.

The bottom line

Get ahead of it while it is still directional. Build the map before you buy anything. Bring your weakest location up to the standard of your best one, because the rule grades on the weakest. Decide what your practice's network should look like on your terms, this quarter, calmly, instead of the week the final rule lands.