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August 20, 2025
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Travis Good

HITRUST Gudie for Startups 2025

This guide provides a strategic roadmap for organizations new to HITRUST, drawing from the latest framework updates and industry best practices. Whether you're a startup preparing for your first enterprise healthcare deal or an established company expanding into regulated industries, understanding HITRUST's evolving landscape is essential for sustainable growth.

The healthcare technology landscape has fundamentally shifted. What once were industry-specific security requirements have evolved into universal expectations for any organization handling sensitive information. In 2025, HITRUST certification has become the gold standard that bridges the gap between compliance complexity and business growth—particularly for companies seeking to establish trust with healthcare partners, secure enterprise contracts, and demonstrate security maturity to investors.

This guide provides a strategic roadmap for organizations new to HITRUST, drawing from the latest framework updates and industry best practices. Whether you're a startup preparing for your first enterprise healthcare deal or an established company expanding into regulated industries, understanding HITRUST's evolving landscape is essential for sustainable growth.

Understanding the 2025 HITRUST Landscape

The HITRUST Common Security Framework (CSF) has undergone significant evolution since its launch in 2007, with the latest version v11.3.0 released in October 2024 focusing on compliance efficiency and optimal resource use. What makes HITRUST particularly valuable in 2025 is its comprehensive harmonization approach—the framework incorporates and harmonizes over 50 authoritative regulations and standards, making your overall compliance workflow efficient.

The latest version includes integration of NIST SP 800-172 for enhanced protections of Controlled Unclassified Information (CUI), preparation for CMMC Level 3 requirements, and inclusion of MITRE Adversarial Threat Landscape for Artificial-Intelligence Systems (MITRE Atlas) mitigations to address security requirements crucial for safeguarding AI systems. These updates reflect the framework's adaptability to emerging threats and regulatory requirements.

The framework's threat-adaptive nature sets it apart from static compliance standards. HITRUST e1 and i1 assessments are designed to be threat-adaptive through the selection of requirement statements that address active cyber security threats based on HITRUST's quarterly reconciliation of cyber threat intelligence to the HITRUST CSF requirements. This means your security controls evolve with the threat landscape rather than remaining static.

The Strategic Business Case for HITRUST

Organizations often approach HITRUST from a purely compliance perspective, but the most successful implementations view it as a strategic business enabler. HITRUST certification is particularly important for organizations that process or store protected health information (PHI) because several HITRUST controls are mapped to HIPAA, but its value extends far beyond healthcare compliance.

Consider the competitive advantages HITRUST provides in today's market. Potential customers, investors, and other stakeholders consider HITRUST certification as proof of advanced security, which enhances your organization's trustworthiness and marketability. For startups seeking to break into enterprise markets, HITRUST certification often serves as a prerequisite for serious consideration by healthcare systems, insurance companies, and other regulated entities.

The framework's comprehensive scope also delivers operational efficiencies. Rather than managing separate compliance programs for HIPAA, GDPR, SOC 2, and other standards, HITRUST provides a unified approach that satisfies multiple regulatory requirements simultaneously. This consolidation becomes particularly valuable as organizations scale and enter new markets with varying compliance requirements.

Choosing Your Assessment Level: A Strategic Decision

HITRUST offers three assessment levels: e1 (Essential), i1 (Intermediate), and r2 (Risk-based), each designed for different organizational maturity levels and business objectives. The choice between these levels should align with your growth strategy and immediate business needs.

HITRUST e1: The Strategic Starting Point

HITRUST e1 is a base-level assessment best suited for small organizations or those with a simpler risk profile and IT infrastructure, encompassing 44 critical controls that ensure foundational security standards for every organization. What makes e1 particularly attractive for startups is its efficiency—organizations can get an e1 certificate in six to eight weeks because of the minimal number of controls.

The e1 assessment serves as an excellent foundation for organizations establishing their security program. If you have an established security program, chances are you already have many of the e1 controls in place, so getting certified shouldn't involve considerable upgrades to your security posture. This makes e1 an ideal entry point for demonstrating security commitment to potential partners while building internal security capabilities.

HITRUST i1: Building Comprehensive Assurance

HITRUST i1 is a more elaborate assessment offering greater assurances, mostly aimed at mid-sized organizations or those with more comprehensive security needs, covering 187 controls, including the 44 from the e1 assessment. The i1 certification positions organizations for more significant business opportunities and demonstrates a mature approach to information security.

Organizations pursuing i1 certification should expect additional effort in technology system updates, process documentation, and policy development. However, this investment pays dividends when competing for larger contracts or seeking investment from security-conscious investors.

HITRUST r2: The Enterprise Standard

As the highest HITRUST certification level, the r2 is intended for organizations with a diverse risk landscape and comprehensive security infrastructure, providing the most advanced security controls and building strong industry credibility. The r2 assessment is risk-based rather than prescriptive, with custom controls based on a risk assessment questionnaire, with over 2,000 controls in total and an average assessment size of 385 controls.

The r2 certification carries significant strategic value—an r2 certificate is valid for two years, providing longer-term certification benefits. Organizations pursuing r2 should have mature security programs and dedicated compliance resources, as the assessment requires extensive documentation and evidence collection.

Preparing Your Organization: The Foundation Phase

Success in HITRUST certification begins long before engaging with external assessors or completing MyCSF forms. The foundation phase involves establishing the organizational capabilities and mindset necessary for effective compliance management.

Conducting a Strategic Security Assessment

Before starting the HITRUST certification process, you must outline your organization's security standing, growth goals, and compliance requirements. This assessment should go beyond technical controls to examine your organization's risk tolerance, resource allocation, and strategic priorities.

Begin with a comprehensive inventory of your existing security capabilities. Document your current IT infrastructure, security policies, access controls, and data protection measures. Assess your current IT infrastructure and document the existence and effectiveness of the relevant controls. This inventory will serve as the baseline for gap analysis and help identify areas requiring immediate attention.

Conducting a Comprehensive Internal Audit

A thorough internal audit forms the cornerstone of effective HITRUST preparation. This audit should systematically evaluate your organization's current capabilities against all 19 HITRUST control domains to identify gaps and prioritize implementation efforts. The audit serves dual purposes: establishing your baseline security posture and creating the foundation for evidence collection activities.

Structure your internal audit to address each HITRUST domain comprehensively. Begin with Information Protection Program to assess your overall security governance framework, then examine Access Control mechanisms to understand how you manage user permissions and authentication. Evaluate your Risk Management processes to determine how effectively you identify, assess, and mitigate security risks across your organization.

Continue the audit by reviewing Security Incident Management capabilities, including detection, response, and recovery procedures. Assess Configuration Management practices to understand how you maintain system security baselines and manage changes. Examine your Cryptographic Controls to ensure data protection meets current standards and regulatory requirements.

Your audit should also evaluate Security Policy documentation and implementation, Personnel Security procedures including background checks and access provisioning, and Physical and Environmental Protection measures. Review your Security Awareness and Training programs to assess staff security knowledge and ongoing education initiatives.

Don't overlook critical operational domains during your audit. Examine Incident Response capabilities beyond initial management to include forensics and lessons learned processes. Assess Business Continuity and Disaster Recovery Planning to ensure operational resilience. Evaluate Third-Party Assurance programs to understand how you manage vendor risks and security requirements.

Technical domains require equally thorough evaluation. Review Audit and Accountability systems to ensure comprehensive logging and monitoring capabilities. Assess Network Protection measures including firewalls, intrusion detection, and network segmentation. Examine Data Protection and Privacy controls to ensure sensitive information receives appropriate safeguards throughout its lifecycle.

Complete your audit with Systems and Communications Protection assessment, covering secure development practices and communication security. Evaluate Configuration Management and Vulnerability Management programs to ensure systems remain secure and current with security patches.

Document your findings for each domain using a consistent framework that identifies current capabilities, existing gaps, and priority levels for remediation. This documentation will guide your implementation roadmap and serve as baseline evidence for your HITRUST assessment.

The assessment should also examine your organizational readiness for sustained compliance efforts. HITRUST certification is not a one-time achievement but an ongoing commitment to security excellence. Consider your team's capacity for documentation, evidence collection, and continuous monitoring activities.

Establishing Your MyCSF Foundation

Creating your company's MyCSF account will be a non-negotiable task before starting your HITRUST compliance journey. MyCSF serves as HITRUST's cloud-based compliance platform, providing the infrastructure for completing assessments, submitting evidence, and managing certification activities.

Setting up MyCSF effectively requires careful planning of user roles, access permissions, and organizational structure within the platform. Consider who within your organization will serve as primary and secondary administrators, and ensure these individuals understand the platform's capabilities and limitations.

Building Your HITRUST Team: Internal and External Resources

Successful HITRUST implementation requires a blend of internal commitment and external expertise. The most effective approach combines dedicated internal resources with strategic use of external specialists to accelerate progress and ensure compliance quality.

Internal Team Development

Your internal HITRUST team should include representatives from security, compliance, legal, and operations functions. The team leader should have authority to make decisions about security investments and policy changes, as HITRUST implementation often requires organizational changes beyond technical controls.

Consider designating a HITRUST champion who will serve as the primary interface with external assessors and maintain ongoing compliance activities. This individual should develop deep familiarity with the framework's requirements and serve as an internal consultant for HITRUST-related questions.

External Assessor Selection

HITRUST certification requires a self-assessment, which is further validated by an external assessor—an individual practitioner or organization authorized by HITRUST to perform validated assessments and review your controls against the framework's requirements. The choice of external assessor significantly impacts your certification timeline, costs, and overall experience.

Although you can complete this step later, it's ideal to find a reputable HITRUST assessor early on in the compliance process. Early engagement with your assessor provides several advantages, including gap identification, timeline planning, and expectation setting for the validation process.

When selecting an external assessor, consider their experience with organizations similar to yours in size, industry, and technology stack. Ask for references from recent clients and understand their approach to evidence validation and quality assurance support.

Scoping Your Assessment: Strategic Decisions with Long-term Impact

Assessment scoping is a considerable challenge in the HITRUST certification process, especially if you choose one of the higher assessment levels that can have 100+ controls. Effective scoping requires balancing comprehensive coverage with practical implementation considerations.

Understanding Scoping Implications

Your scoping decisions will impact not only your initial certification effort but also ongoing compliance activities and future assessment cycles. You must clearly outline the systems, devices, and other components of your security infrastructure that the assessment will cover.

Consider how your technology infrastructure may evolve over the next two years. Systems and applications added after certification must be evaluated for their impact on your HITRUST scope, and significant changes may require reassessment activities.

Leveraging Inheritance Opportunities

One of HITRUST's most powerful features is its inheritance capability, which allows organizations to inherit controls from cloud service providers and other third parties rather than implementing them independently. External Inheritance can be used between v11 assessments and v9.1 – v9.6.2 assessments, providing flexibility in leveraging existing security investments.

Investigate inheritance opportunities with your cloud providers, managed service providers, and other critical vendors. Many major cloud platforms maintain HITRUST certifications that can be inherited for specific controls, reducing your implementation burden while maintaining compliance coverage.

The Readiness Assessment: Your Preparation Gateway

A readiness assessment involves a gap analysis that helps you compare your controls to HITRUST's requirements. While optional, readiness assessments provide crucial insights that can significantly accelerate your validated assessment and reduce costs.

Conducting Effective Gap Analysis

The readiness assessment serves as your final preparation before entering the formal validation process. While not a mandatory step of the certification process, it's highly beneficial for ensuring your controls meet the necessary standards, considerably reducing the time and effort you spend on a validated assessment.

Approach the readiness assessment as an opportunity to stress-test your compliance program. Challenge your control implementations, question your evidence quality, and identify potential assessor concerns before they become formal findings.

Evidence Collection Strategy

As you work to optimize your controls, make sure to collect all the evidence that validates their existence and performance—the external assessor will use it later to verify your self-assessment. Evidence collection often represents the most time-consuming aspect of HITRUST preparation.

Common types of evidence include written, verbal, observed, and digital forms of validation. Develop standardized approaches for each evidence type, including document templates, interview protocols, and automated collection procedures where possible.

Implementing Controls: Beyond Checkbox Compliance

HITRUST control implementation should focus on creating sustainable security capabilities rather than simply meeting assessment requirements. The most successful organizations use HITRUST as a framework for building comprehensive security programs that deliver ongoing business value.

Understanding the Control Domains

Your controls must be in line with HITRUST's 19 control domains: Information Protection Program, Endpoint Protection, Portable Media Security, Mobile Device Security, Wireless Security, Configuration Management, Vulnerability Management, Network Protection, Transmission Protection, Password Management, Access Control, Audit Logging & Monitoring, Education, Training and Awareness, Third Party Assurance, Incident Management, Business Continuity & Disaster Recovery, Risk Management, Physical & Environmental Security, and Data Protection & Privacy.

Each domain represents a critical aspect of information security, and effective implementation requires understanding the interconnections between domains. For example, access control decisions impact audit logging requirements, while configuration management affects vulnerability management capabilities.

Scoring Your Controls Effectively

Scoring is performed using HITRUST's Control Maturity Scoring Rubric—a visual tool designed to help organizations grade controls according to the PRISMA model. The PRISMA model evaluates five factors: policies, procedures, implementation, monitoring and measurement, and corrective actions.

If you opt for an e1 or i1 assessment, you only need to score the implementation level (#3) of your controls. For r2 assessments, you must score all five levels. Understanding these scoring requirements helps prioritize implementation efforts and ensure adequate documentation for validation.

The Validation Process: Working with Your External Assessor

The validation process represents the formal evaluation of your HITRUST implementation. Success depends on effective collaboration with your external assessor and thorough preparation of evidence and documentation.

Managing the Validation Timeline

During the assessment stage, you'll score each requirement statement using the evaluated PRISMA maturity levels, and after you've scored all the in-scope requirement statements, an external assessor must validate their accuracy through extensive assessment fieldwork.

Validation activities include personnel interviews, policy reviews, technical assessments, and evidence examination. Prepare your team for these activities by conducting internal dry runs and ensuring all stakeholders understand their roles in the validation process.

Quality Assurance and Final Review

Quality assurance is the final stage before your organization receives a HITRUST certificate, performed by a HITRUST QA analyst, who will scrutinize all aspects of the assessment to determine whether your controls pass the required standards.

The QA process may result in tasks assigned to your organization or the external assessor. General tasks are requests or instructions to address a particular QA concern, while proposed tasks are suggested changes that should be considered. Respond to QA tasks promptly and thoroughly to avoid delays in certificate issuance.

Technology and Automation: Accelerating Your Journey

Modern HITRUST implementation benefits significantly from automation and integrated technology solutions. Organizations that leverage compliance automation tools like Vanta have more streamlined evidence collection and control monitoring processes, which can help them get ready for e1 certification in as little as 80 hours.

Leveraging Compliance Automation

Vanta automates up to 80% of the certification requirements and is the first pre-built, custom solution for HITRUST, including the controls, documents, and policies necessary to demonstrate your commitment to safeguarding sensitive data. Automation platforms can significantly reduce the manual effort required for evidence collection, control monitoring, and documentation management.

Consider automation tools that integrate with your existing technology stack and provide real-time visibility into compliance status. The ability to continuously monitor control effectiveness and automatically collect evidence reduces the burden of ongoing compliance activities.

Integration with MyCSF

Vanta integrates with HITRUST's audit portal, MyCSF, allowing you to automatically import evidence into their audit platform. This integration streamlines the submission process and reduces the manual effort required for evidence management during validation.

Planning for Ongoing Compliance

HITRUST certification represents the beginning rather than the end of your compliance journey. Successful organizations develop sustainable approaches to maintaining certification and leveraging their security investments for continued business growth.

Maintenance and Renewal Planning

e1 and i1 certificates are valid for one year, while r2 certificates are valid for two years with an interim assessment requirement. Plan your renewal activities well in advance, considering how your organization and technology stack may evolve between certification cycles.

Develop procedures for evaluating the impact of organizational changes on your HITRUST scope and controls. Significant changes in technology, processes, or business activities may require assessment updates or additional validation activities.

Leveraging Cross-Framework Benefits

Vanta's gap assessment automatically cross-references other supported frameworks, including up to 50% of SOC 2 and ISO 27001, for controls you've already implemented. Your HITRUST investment can serve as the foundation for additional compliance frameworks, creating efficiencies across your entire compliance program.

Timeline and Resource Planning

Understanding realistic timelines for HITRUST certification helps set appropriate expectations and allocate resources effectively. On average, the certification process should last between three and eighteen or more months, depending on what certification tier you're targeting.

Accelerating Your Timeline

Organizations on the lower end of the time frame are those that prepare for the assessment well in advance—they typically experience minimal to no back-and-forth during the assurance process. Thorough preparation, early assessor engagement, and automation tools can significantly reduce certification timelines.

Consider conducting readiness assessments, implementing automation tools, and establishing clear project management processes to accelerate your certification timeline while maintaining quality.

The Workstreet Recommended Pathway: e1 to r2 Progression Strategy

At Workstreet, our experience guiding hundreds of organizations through HITRUST certification has revealed a clear pattern among the most successful implementations. Rather than attempting to achieve the highest certification level immediately, we recommend a strategic progression approach that begins with HITRUST e1 and advances systematically toward r2 certification.

Why Start with e1: Building Your Foundation

The e1 assessment serves as an ideal foundation for several strategic reasons. First, it allows organizations to establish core security capabilities without overwhelming internal resources. The 44 critical controls in e1 represent the essential security foundations that every organization should have in place, regardless of industry or size.

Starting with e1 also provides crucial organizational learning. Your team will gain familiarity with HITRUST's assessment methodology, evidence collection requirements, and quality assurance processes. This experience proves invaluable when progressing to more complex certification levels, as your organization will understand the rhythm and expectations of HITRUST validation.

From a business perspective, e1 certification delivers immediate value while you're building toward more comprehensive certification. Many potential partners and customers view e1 as sufficient demonstration of security commitment for initial business relationships. This allows you to begin capturing business value from your security investments while continuing to mature your capabilities.

The Strategic Progression to r2

Our recommended pathway involves achieving e1 certification first, then leveraging that foundation to pursue r2 certification within 12-18 months. This approach skips i1 certification deliberately, as the i1 controls are largely encompassed within the r2 assessment scope.

The progression strategy provides several advantages. Your e1 implementation establishes 44 controls that will be inherited into your r2 assessment, providing a significant head start on the larger certification effort. The organizational capabilities developed during e1—evidence collection procedures, stakeholder engagement processes, and assessor collaboration skills—transfer directly to r2 preparation.

Additionally, the progression approach allows for strategic timing of your r2 certification to align with business milestones such as major customer acquisitions, funding rounds, or market expansion initiatives. The two-year validity period of r2 certification provides longer-term stability for business development activities.

Leveraging Workstreet's Vanta HITRUST Partnership

Workstreet serves as a preferred HITRUST partne for Vantar, bringing deep expertise in the framework's nuances and evolution. Our team has guided organizations through every certification level and understands the strategic implications of different implementation approaches. This partnership enables us to provide not just technical compliance support, but strategic guidance on leveraging HITRUST for business growth.

Our approach integrates HITRUST preparation with broader security program development, ensuring that your certification efforts build sustainable capabilities rather than simply meeting assessment requirements. We help organizations understand how HITRUST controls support business objectives and create operational efficiencies beyond compliance.

Preferred Assessor Network

Through our extensive HITRUST experience, Workstreet has developed relationships with preferred HITRUST assessor partners who share our commitment to quality and efficiency. These assessors understand our methodology and can work seamlessly with our preparation processes to accelerate certification timelines while maintaining rigorous standards.

Our preferred assessor network includes firms with specialized expertise in different industry verticals and organization sizes. This allows us to match clients with assessors who understand their specific challenges and can provide targeted guidance throughout the validation process. The established relationships also facilitate smoother communication and more predictable timelines.

Working with Workstreet's preferred assessor network provides additional advantages including coordinated project management, streamlined evidence collection processes, and proactive identification of potential quality assurance issues. Our assessor partners understand our preparation methodology and can provide more efficient validation services as a result.

Conclusion: Building Security Excellence Through HITRUST

HITRUST certification in 2025 represents more than regulatory compliance—it's a strategic investment in organizational security maturity and market credibility. The framework's evolution to address emerging threats, AI security concerns, and evolving regulatory requirements ensures its continued relevance in the dynamic threat landscape.

Organizations new to HITRUST should approach certification as an opportunity to build comprehensive security capabilities that deliver ongoing business value. By understanding the framework's strategic implications, preparing thoroughly, and leveraging available automation tools, organizations can achieve certification efficiently while establishing the foundation for sustained security excellence.

The investment in HITRUST certification pays dividends through enhanced customer trust, competitive advantages in regulated markets, and operational efficiencies across compliance activities. As healthcare technology continues to evolve and security requirements become more stringent, HITRUST certification provides the foundation for sustainable growth in regulated industries.

Success in HITRUST requires commitment, planning, and the right combination of internal capabilities and external expertise. Organizations that approach HITRUST strategically—viewing it as a business enabler rather than a compliance burden—position themselves for long-term success in the evolving healthcare technology landscape.

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