HIPAA Compliance Readiness Checklist

Preparing for Windows 10 End-of-Life (EOL) and Avoiding HIPAA Violations

Target Audience: Healthcare providers, behavioral health clinics, private practices, and other HIPAA-covered entities

1. Inventory All Windows Devices

• Identify all workstations, laptops, tablets, and servers running Windows 10
• Document device users, department, and role
• Classify based on PHI access level (e.g., access to EHR, billing, email)

2. Evaluate Risk Under HIPAA Security Rule

• Assess each Windows 10 device for risk if left unpatched after October 14, 2025
• Document how these risks could compromise Confidentiality, Integrity, or Availability of ePHI
• Review with your HIPAA Security Officer or compliance consultant

3. Plan and Budget for Migration

• Determine if existing hardware supports Windows 11
• Develop a rollout plan for replacements or upgrades
• Allocate budget and timeline for execution before Q2 2025

4. Identify Required IT Support or Vendor Involvement

• Coordinate with IT team or MSP to schedule upgrades
• Ensure antivirus, endpoint protection, and backup tools are compatible
• Define downtime windows for upgrades with minimal disruption

5. Update HIPAA Documentation

• Revise your Security Risk Analysis (SRA) to include Windows 10 deprecation
• Update your Written Information Security Program (WISP) or HIPAA Security Policies
• Document mitigation steps for risk areas (e.g., EOL systems awaiting upgrade)

6. Train Staff on Security Risks

• Notify team members of the Windows 10 EOL timeline
• Train staff on potential phishing and system alerts during transition
• Provide updated procedures if using temporary devices or software

7. Implement Interim Security Controls (If Upgrade Is Delayed)

• Isolate EOL systems from core networks
• Limit PHI access on unsupported machines
• Enable additional logging and endpoint monitoring

8. Confirm Full Decommissioning by September 2025

• Set a hard cutoff date for all Windows 10 systems to be removed or replaced
• Validate that no ePHI is processed or stored on these systems after cutoff
• Document decommissioning and wipe securely

9. Schedule a Compliance Review

• Perform a post-upgrade HIPAA Security Evaluation
• Conduct vulnerability scanning or third-party audit
• Store results for OCR or audit readiness

Bonus: Schedule Your Free Compliance Readiness Call