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Getting to a Readiness Target Ahead of an Enterprise Contract

A growing healthcare technology company needs to meet HIPAA obligations to win a major enterprise contract. Acting as Virtual CISO, Summit would build and lead the security program toward its readiness target, on a plan built around a one-quarter deadline.

PlaybookHealthTech · Compliance

This playbook at a glance

Healthcare & HealthTech
  • 3steps in the first 30 days
  • 2after day 30
  • 4decision points
  • 3deliverables at the end

The trigger

The situation a company is in when this conversation starts.

A health-tech company has won the attention of a large health system. The system's procurement process requires evidence of a HIPAA-compliant security program, including a documented risk analysis, written policies, and a business associate agreement the company can actually honor. The company has capable engineers and good instincts, but no security leader, no written program, and a contract deadline one quarter away.

The first 30 days

How Summit would run the work, in order.

  1. Summit would step in as Virtual CISO with a single objective for the quarter: be able to answer the health system's security review truthfully and with evidence.

  2. Weeks 1–2: the HIPAA risk analysis required by 45 CFR §164.308(a)(1)(ii)(A), scoped to the systems that store or transmit protected health information.

  3. From week 3: the policy set the review will ask for, written to match how the company actually works, and the handful of technical controls the risk analysis shows are missing, prioritized by what an auditor checks first.

After day 30

  1. Through week 8: the policy set and the missing controls completed.

  2. Weeks 9–12: evidence collection, a mock review using the health system's own questionnaire, and a briefing for the executive who would sign the business associate agreement.

The decision points

The calls your leadership makes along the way. Summit brings the evidence and a recommendation; the decision stays yours.
  1. Which systems are in scope for the risk analysis, based on where protected health information is stored or transmitted.
  2. Which missing controls are fixed before the review, and which go on the remediation log with a date.
  3. Whether the business associate agreement's security obligations can be honored as written, before the executive signs it.
  4. After the contract decision: whether the Virtual CISO engagement continues at a lower level to keep the program current rather than letting it decay after the deal.

What you’d have at the end

Deliverables written to be used, not filed.
  1. A completed, documented HIPAA risk analysis with a remediation log the company can keep current.
  2. A policy and procedure set covering the Security, Privacy, and Breach Notification Rules, with an owner assigned to each.
  3. An evidence pack organized to the health system's questionnaire, and a review of the business associate agreement's security obligations before signature.

The service behind it

Virtual CISO Leadership

This playbook draws on Summit’s Virtual CISO Leadership service. Every engagement is scoped to the company in front of us, so the order and the length can change.

How an engagement runs: the 5 stages

  1. First call
  2. Scope
  3. Discovery and baseline
  4. Analysis and plan
  5. Readout and handover
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