Top 5 HIPAA Mistakes Small Practices Make ( and How To Fix Them)

When running a small clinic or private practice, compliance is often the forgotten task while resources are focused on providing quality patient care. But regulatory violations—especially HIPAA violations—don’t just happen at large health systems. In fact, small practices are often the most vulnerable.

At ClientShield, we help resource-limited and minority-owned practices build privacy programs that actually work. Below are five of the most common HIPAA violations we see—and simple, proactive ways to fix them.

1) Using Outdated or Incomplete Notice of Privacy Practices (NPP)

Problem: Many practices rely on generic NPPs, if any at all, that lack key language about patient rights, complaints, and digital communication.

What’s the Big Deal: Covered entities are required to provide patients with an NPP at their first visit, upon request, and to make it publicly available on their websites (45 CFR § 164.520). The NPP is also one of the first documents requested when a patient raises a concern.

The Fix:

• Review and update your NPP annually or after significant changes;

• Include patient rights, your Privacy Officer’s contact information, and use plain-language summary; and

• Ensure the NPP is clearly posted on your website and distributed to ALL patients at intake.

  ClientShield Tip: Grab our free, fillable NPP template to save time and stay compliant.

2) No Written Privacy Policies or Procedures

Problem: Small teams often rely on “common sense” or informal direction rather than formal documentation.

What’s the Big Deal: HIPAA requires covered entities to maintain written privacy policies. Failing to implement a clear, substantive policy can result in financial penalties during audits or investigations (45 CFR § 164.530(i)).

The Fix:

• Create tailored privacy policies that reflect your practice size and daily workflow;

• Include key areas like access requests, data retention, individual rights, and disciplinary action; and

• Review and update policies annually.

  ClientShield Tip: Customizable template, including policy index to help structure your documentation, are available in our download library.

3) Minimal or One-Time Employee Training

Problem: Training only occurs during New Hire Orientation, if at all, and staff aren’t regularly reminded of privacy expectations.

What’s the Big Deal: Staff errors are the #1 cause of HIPAA violations. Ongoing training is your first line of defense.

The Fix:

• Train ALL employees at the time of hire and at least annually thereafter;

• Cover real-life scenarios such as misdirected faxes, commingling of paperwork, and email mishaps; and

• Keep track of training dates and completion logs.

  ClientShield Tip: Our quarterly refreshers and customizable training slides make it easy to stay on track without losing productivity.

4) Weak Access Controls ad Authorization Practices

Problem: PHI access isn't restricted based on role, documents are faxed without confirmation, and authorization forms are outdated or missing.

What’s the Big Deal: HIPAA’s Minimum Necessary Rule (45 CFR § 164.502(b)) requires limiting access and disclosures to only the PHI necessary for a given task. Unrestricted access or sloppy disclosures are high-risk.

The Fix:

• Set up role-based access in your systems (e.g., front desk vs. billing staff);

• Always very identity before releasing PHI; and

• Use current authorizations forms, especially for external disclosures.

  ClientShield Tip: Our compliant, multi-use PHI Authorization Forms work across all 50 states, including CA and TX.

5) No Privacy Incident or Breach Response Plan

Problem: Practices often panic when something goes wrong - a misdirected phone, lost/stolen device, or patient complaint.

What’s the Big Deal: HIPAA requires documented processes for responding to privacy incidents and reporting breaches when necessary (45 CFR § 164.530(d), (j)). Without a plan, your response may cause more harm than the incident itself.

The Fix:

• Assign a Privacy Officer (even if it’s you!);

• Create a simple incident réponse plan with reporting steps; and

• Track all incidents, even those that don’t qualify as reportable breaches.

  ClientShield Tip: The HIPAA Starter Kit includes a Breach Triage Worksheet to help you assess and document privacy incidents quickly.

HIPAA compliance doesn’t have to be overwhelming or expensive. With the right tools and a proactive mindset, small practices can build programs that protect patients and reduce liability.

Want to start with the basics?

Download our free HIPAA Starter Kit designed specifically for small and solo providers.