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NYDOH Cybersecurity Regulations: What Healthcare Providers Need to Know in 2025

by Rebecca Kappel on December 19, 2024

10 NYCRR 405.46: NY’s New Hospital Cyber Regulation

Hospitals are no strangers to health data privacy laws like HIPAA. But New York’s new cybersecurity regulations take things to the next level. Finalized by the New York State Department of Health (NYDOH) in October 2024, these laws aim to fill gaps left by existing frameworks. They address data privacy and the escalating threat of cyberattacks targeting healthcare institutions. The new healthcare cyber regulations will go into effect in October 2025.

How is this Different from HIPAA? While HIPAA mandates the protection of electronic health information (ePHI) through administrative, physical, and technical safeguards, it doesn’t go into the weeds of specific cybersecurity practices. The new NY regulations, however, go further by requiring hospitals to implement:

Tailored cybersecurity programs,
Designation of a Chief Information Security Officer (CISO),
Penetration testing,
Mandatory breach reporting within 72 hours.

For many hospitals, these regulations signal a shift from compliance-focused privacy to proactive cybersecurity. They represent a necessary evolution, as inconsistent practices and limited oversight have left gaps that ransomware attacks and data breaches continue to exploit nationwide. These new requirements align with a growing trend in healthcare: recognizing cybersecurity as foundational to both patient safety and institutional resilience.

In the sections ahead, we’ll explore what makes these new cyber rules in hospitals unique, how they compare to HIPAA and other frameworks, and what hospitals need to do to comply.

NYDOH Cybersecurity Regulations: What Healthcare Providers Need to Know in 2025

What You Need to Know About 10 NYCRR 405.46

For those unfamiliar with the NYCRR, it’s a collection of administrative rules and regulations in New York State designed to implement laws passed by the legislature. 10 NYCRR 405.46 is the specific regulation hospitals must follow to ensure compliance with these updated cybersecurity standards. It provides clear and actionable steps hospitals must take, including establishing a comprehensive cybersecurity framework.

What’s New in the NY Cybersecurity Regulations?

The most significant updates to New York’s cybersecurity rules for hospitals can be grouped into several key areas:

Cybersecurity Program Implementation

Hospitals are now required to implement a comprehensive cybersecurity program that goes beyond simply meeting minimum standards. This program must include regular risk assessments, establishing defensive infrastructure, and ongoing vulnerability management. Specific attention is given to email-based threats, which are responsible for a growing number of security incidents in healthcare.

Appointment of a Chief Information Security Officer (CISO)

Under the new New York cyber security law, hospitals must designate a senior staff member with appropriate qualifications to serve as the CISO. This individual will oversee cybersecurity activities, ensuring compliance with the new regulations and responding to emerging risks. The CISO is also responsible for presenting a cybersecurity risk report to the hospital’s governing body annually, detailing material cybersecurity risks and mitigation strategies.

Multi-factor Authentication (MFA) and External Access Controls

To reduce the risk of unauthorized access to sensitive data, hospitals must implement multi-factor authentication (MFA) for external access to their internal networks. This requirement underscores the need for robust access control mechanisms, especially as remote work and telehealth services continue to expand.

Penetration Testing and Ongoing Risk Assessments

The regulations stress the importance of proactive testing and assessment. Hospitals must conduct regular penetration tests and risk assessments to identify vulnerabilities. This should be done at least annually, but hospitals are encouraged to adopt continuous monitoring approaches to stay ahead of potential threats.

Incident Reporting

One of the more urgent provisions of the new regulations is the mandate to report significant cybersecurity incidents within 72 hours of discovery. This is a notable departure from previous guidelines, with longer reporting windows. The emphasis on rapid reporting ensures that healthcare organizations act quickly to mitigate threats before they escalate into more severe breaches.

Third-Party Cybersecurity Oversight

Hospitals increasingly rely on third-party vendors for various services, making it essential to ensure that these partners meet cybersecurity standards. The regulations require hospitals to formalize agreements with third-party vendors, specifying security measures to ensure they don’t become weak points in the organization’s defenses.

Record Retention for Cybersecurity Logs

Hospitals must retain detailed records of their cybersecurity activities, including events logs, for at least six years. This includes audit trails and logs of any actions taken in response to security events. The retention requirement underscores the need for hospitals to maintain a historical record that can be referenced during an audit or investigation.

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Learn more about how to be compliant with NYDOH Cybersecurity Regulations

How Will These Changes Affect Hospitals?

Implementing these regulations will require hospitals to invest in new technologies and adjust their internal processes. The new NY cyber rules will create additional responsibilities for IT departments, cybersecurity teams, and hospital executives. For instance:

Training and Awareness: With an increased emphasis on risk assessments and incident reporting, hospitals must ensure that staff are adequately trained to identify potential cyber threats. This may involve introducing regular training sessions, simulations, and awareness campaigns.
Cost and Resource Allocation: Hospitals will face financial challenges as they invest in updated systems and additional personnel to meet these requirements. Designating a CISO and ensuring compliance with multi-factor authentication and regular penetration testing will necessitate a strategic investment and a shift in cybersecurity resources.
Enhanced Communication and Transparency: Hospitals will need to improve their communication structures with the new requirement to report incidents swiftly. Developing efficient internal workflows for identifying, escalating, and reporting cybersecurity threats will be key in minimizing the impact of incidents and maintaining trust with patients and stakeholders.

Comparative Analysis

While federal frameworks like HIPAA and HITECH have long set healthcare data privacy and security standards, New York’s regulations take a more prescriptive approach. For instance:

Reporting Timelines: HIPAA requires entities to notify affected individuals and the Department of Health and Human Services (HHS) of breaches within 60 days. New York’s 72-hour reporting window is significantly stricter, reflecting the need for immediate action in containing cyber threats.
Scope of Responsibilities: Unlike HIPAA, which focuses on protecting Protected Health Information (PHI), New York’s law mandates broader cybersecurity measures, such as regular penetration testing and multi-factor authentication, to mitigate risks proactively.
Role of the CISO: While HIPAA emphasizes accountability, New York’s regulations require hospitals to appoint a Chief Information Security Officer (CISO) formally. This ensures that cybersecurity receives focused leadership and ongoing oversight at the executive level.

In contrast, California’s healthcare cybersecurity laws focus more on general data privacy under the California Consumer Privacy Act (CCPA) and do not prescribe specific technical measures. This makes New York’s approach more stringent, positioning it as a potential model for other states.

Implications for Smaller Hospitals

Smaller hospitals and rural healthcare facilities may find these regulations particularly challenging. With limited budgets and IT staff, these institutions often lack the resources to implement advanced cybersecurity measures. For example, the cost of hiring a qualified CISO or conducting regular penetration testing can strain already tight budgets.

However, neglecting these measures could prove costlier in the long run. A single ransomware attack can cripple operations and lead to significant financial losses, not to mention the potential harm to patients and reputational damage.

To support compliance, New York could explore providing grants or subsidies, especially for rural hospitals, to offset the costs of implementing these measures. Organizations like the American Hospital Association (AHA) have advocated for such initiatives, recognizing the disproportionate burden smaller facilities face. Hospitals can also consider pooling resources by collaborating with regional healthcare consortia to share cybersecurity expertise and infrastructure.

What Are the Implications for Cyber Insurance?

Along with the implementation of these cybersecurity requirements, hospitals should also pay attention to the evolving landscape of New York insurance laws. Insurers are increasingly focusing on cybersecurity risk when assessing policies, and failure to meet state requirements could impact coverage. Hospitals may need to provide proof of compliance with the new regulations to secure or renew their cyber insurance policies.

Preparing for Compliance: What Hospitals Need to Do Now

To comply with the new New York cybersecurity requirements, hospitals should begin by conducting a thorough assessment of their current cybersecurity posture. This should include:

Designate a CISO (or leverage shared services for smaller hospitals).
Review access controls and implement MFA for all external network access.
Invest in automated penetration testing and risk assessment tools to ensure continuous vulnerability management.
Evaluate third-party vendors and ensure they meet cybersecurity standards through updated contracts and formal agreements.
Streamline incident response procedures to ensure incidents can be reported within 72 hours, minimizing damage.

Building Resilience and Trust in Healthcare

Patients entrust hospitals with their most sensitive information during some of the most vulnerable moments in their lives. These new rules, outlined in 10 NYCRR 405.46, are vital to ensuring that trust is well-placed.

Studies have found that 92% of healthcare organizations surveyed experienced at least one cyber attack in the past year, with the average cost of a breach surpassing $10 million per incident. By embracing these changes, hospitals can build a foundation for resilience and deliver on the ultimate promise of healthcare: to protect and care for those who need it most.

Meeting these requirements may feel like an uphill climb for hospitals—but it doesn’t have to be. Centraleyes offers the most extensive state-specific library of frameworks available. With its automation capabilities, hospitals can streamline assessments, proactively identify vulnerabilities, and generate real-time insights.