Over the years of working with healthcare organizations adopting AWS, I’ve noticed that many teams struggle with the same pitfalls when it comes to HIPAA compliance. These aren’t rare or unusual mistakes; they happen frequently, even with experienced teams. The encouraging part is that each one can be avoided with the right practices and a proactive approach.
Here are the most common AWS HIPAA compliance mistakes, along with practical ways to prevent them.
One of the most common problems I come across is misconfigured access. Teams often grant overly broad permissions to users and roles, thinking it will save time. But in the world of healthcare data, that’s a recipe for disaster. If every user can access everything, the risk of a data breach skyrockets.
Always apply the principle of least privilege. Give users and applications only the permissions they truly need, nothing more. Use IAM roles instead of static credentials and review access policies on a regular basis. Adding automated alerts for unusual permission escalations can also save you from future headaches.
Another frequent oversight is failing to properly encrypt Protected Health Information (PHI). Some teams assume AWS encrypts everything automatically, which is not the case by default. This oversight leaves sensitive data vulnerable in transit and at rest.
Turn on encryption everywhere. Use AWS KMS to manage encryption keys for services like S3, EBS, and RDS. For data in transit, enforce TLS/SSL. And don’t stop there, make encryption the default policy for your entire AWS environment, so it’s never left to chance.
It’s surprising how often organizations run workloads containing PHI on AWS without signing a BAA. Without it, they are technically out of HIPAA compliance, regardless of how secure their environment may be.
Before moving any PHI into AWS, sign the Business Associate Agreement (BAA) with Amazon. It’s a non-negotiable step. Without it, nothing else you do will matter from a compliance perspective.
It’s common to get excited about new AWS services, but not all of them fall under the HIPAA BAA. Teams sometimes deploy PHI workloads on services that aren’t approved, putting compliance at risk.
Stick to the HIPAA-eligible AWS service list, which Amazon publishes and updates regularly. If a service isn’t on that list, don’t use it to process or store PHI. When in doubt, always double-check eligibility before rolling out a new service.
If you can’t see what’s happening in your environment, you can’t protect it. Many organizations skip enabling detailed logging or fail to monitor for unusual behavior. This leaves blind spots where threats can go unnoticed.
Turn on CloudTrail across all regions, use CloudWatch for real-time metrics, and enable GuardDuty for threat detection. Logging should not be optional; it should be a built-in habit. And don’t just collect logs; review them regularly and set up automated alerts for suspicious activities.
Few things make headlines faster than exposed S3 buckets. Unfortunately, this continues to be a very common mistake. PHI is often stored in buckets with public access turned on, or without encryption enabled.
Use the S3 Block Public Access setting to prevent accidental exposure. Apply strict bucket policies, enforce server-side encryption, and take advantage of S3 Access Points for fine-grained control. A simple configuration review can save you from a costly breach.
HIPAA doesn’t just demand protection; it also requires availability. Many teams focus so much on security that they neglect proper backup and disaster recovery planning. Without a tested recovery strategy, a system outage can be just as damaging as a breach.
Set up automated backups for databases using RDS, EBS snapshots, and enable S3 versioning for file storage. More importantly, test your disaster recovery plan regularly. It’s not enough to have backups; you must be confident you can restore them when needed.
Single-factor authentication is another common oversight. In some cases, even root accounts are left without multi-factor authentication (MFA). That’s a glaring vulnerability in any environment, let alone one holding PHI.
Enforce MFA for every account, especially root and admin users. Rotate access keys regularly and adopt strong password policies. AWS IAM Identity Center (formerly SSO) can also simplify secure authentication across accounts.
Leaving ports open, exposing databases to the internet, or running workloads in a flat VPC design are mistakes that surface repeatedly. These configurations make it far too easy for attackers to gain entry.
Follow a defense-in-depth strategy. Segment your networks using VPCs and subnets, restrict inbound and outbound traffic with security groups and NACLs, and leverage PrivateLink or VPNs to connect securely. Always minimize your internet-facing endpoints.
Finally, one of the biggest pitfalls is assuming compliance is a one-time setup. Too often, teams configure their AWS environment for HIPAA once and then forget about it. Compliance isn’t static, it requires continuous monitoring and regular assessments.
Conduct periodic risk assessments and compliance audits. Use AWS Artifact to access compliance reports and keep documentation updated. More importantly, create a culture of accountability where compliance is an ongoing responsibility, not just a checkbox.
HIPAA compliance in AWS is less about complex technology and more about consistency. The same mistakes surface again and again because they’re often overlooked in the rush to move fast. Addressing them doesn’t require reinventing the wheel, it requires discipline, regular reviews, and a culture that treats compliance as part of everyday operations.
At the same time, navigating AWS can be complex, and that’s where the support of AWS consultancy services proves valuable. With the right expertise, organizations can avoid common missteps, strengthen their security posture, and gain confidence that their environment is aligned with HIPAA requirements.
