Healthcare organizations are facing a perfect storm: rising cyberattacks, expanding regulatory demands, and increasingly thin operating margins. Small healthcare systems feel the impact of these factors even more, yet an increasing number are doing so without Chief Information Security Officers (CISOs). Black Book Research found — in its Q1-Q2 2025 cybersecurity readiness survey — that 68% of small and rural healthcare organizations across the U.S. do not employ a full-time CISO.¹

At the same time, healthcare remains the most expensive industry for cyber breaches, according to IBM’s Cost of a Data Breach Report 2025.² “At USD 7.42 million, healthcare recorded the highest average breach cost among industries for the 12th consecutive year,” says the report. Healthcare breaches also took the longest to “identify and contain at 279 days.”

These figures make the lack of a CISO look even more dangerous, but a missing CISO doesn’t have to translate to heightened risk. Healthcare executives responsible for cybersecurity can maintain a strong security posture — while staying compliant — with the right structure, processes, and external support. Learn how here.

 

1. Create a Clear, Executive-Level Security Governance Model

A CISO typically acts as the unifying point between IT, compliance, clinical stakeholders, and the board. Without this role, ambiguity about “who owns what” can create governance gaps.

Healthcare leaders should establish:

• A documented governance structure that defines decision rights, escalation paths, and responsibilities across IT, compliance, and operations.
• A security review cadence that keeps leadership aligned on risks, incidents, and regulatory changes.
• A single executive who steers decision-making and ensures follow-through.

If you have no executive on staff with security experience, consider working with a third-party partner that offers flexible cybersecurity services or fractional CISO options.

 

2. Double Down on Compliance Visibility

Healthcare regulations are tightening. The US Department of Health and Human Services (HHS) Office for Civil Rights (OCR) has added enforcement actions under HIPAA, reinforcing the focus on core HIPAA compliance obligations, according to reports.³ Additionally, some state laws go beyond HIPAA mandates.

Healthcare executives should:

• Inventory all current compliance frameworks that the organization touches, such as HIPAA, state privacy laws, PCI, etc.
• Investigate and document compliance gaps tied to operational and financial risk.
• Assign each requirement to a designated internal owner — even if they rely on an external partner — so your organization stays ahead of regulatory changes.

 

3. Strengthen Identity and Access Controls

Identity-related weaknesses remain one of the most common sources of healthcare breaches — yet they are among the most preventable.

Take these actions:

• Enforce multi-factor authentication (MFA) everywhere.
• Review and remove dormant accounts on a designated cadence.
• Implement role-based access models.
• Monitor privileged access.

The risk reduction you’ll see from these simple steps is very high compared to their implementation effort.

 

4. Build Repeatable Incident Readiness Processes

You may have an incident response plan, but do you have a practiced readiness process? Such a program ensures your plan actually works under pressure — requiring your organization to walk through and test the plan.

Here’s what you can do to establish your readiness program:

• Conduct realistic tabletop exercises that walk through plausible cyber incidents.
• Update your incident response plan whenever you add or retire vendors, change your EHR, or onboard new leaders.
• Practice identifying incidents that trigger HIPAA or other state-level rules.

Make sure one officer or partner maintains your cycle of testing and updating.

 

5. Leverage External Expertise as Needed

A non-CISO can do their best, but they simply won’t be able to own every component of cybersecurity or govern every moving part. If your organization’s resources are spread thin or you have no security expertise within your walls, it’s a good ideal to turn to a fractional CISO or other third party that can offer security guidance and tools in a flexible model.

Look for a partner that:

• Takes the time to understand your organizations needs and goals. (Avoid cookie-cutter approaches.)
• Offers virtual CISO services in a model that fits your budget.
• Has a proven history of healthcare security experience.
• Offers support for compliance management.

 

No CISO? No Problem.

You don’t need to hire a full-time security executive to adequately face today’s threats and cyber challenges. Using the five elements above and the expertise of an outside partner, your organization can establish a perfectly effective security posture that keeps you compliant.

GuideIT has 30+ years of experience helping healthcare organizations shore up security and stay compliant. We offer flexible, AI-powered security programs and virtual CISO options as well as compliance training to help your teams maintain audit-readiness. Learn more about our security partnership here or schedule a free security consultation with our experts.

• ¹ https://govhealth.distilinfo.com/2025/07/10/rural-healthcare-cybersecurity/
• ² https://www.ibm.com/reports/data-breach
• ³ https://www.nixonpeabody.com/insights/articles/2025/06/12/2025-hipaa-enforcement-tally-rises-following-three-new-settlements