Is HIPAA Training Required Every Year?

By the Comodo Technology training team · October 5, 2026 · 5-minute read

What the HIPAA rules actually say

Two parts of HIPAA cover staff training:

• The Privacy Rule (45 CFR §164.530(b)) requires you to train every member of your workforce on your privacy policies. New staff must be trained within a reasonable period after they join, and affected staff must be retrained when a policy changes in a material way.
• The Security Rule (45 CFR §164.308(a)(5)) requires a security awareness and training program for all staff, including management. It lists periodic security reminders, protection from malicious software, log-in monitoring and password management.

Notice the word “periodic.” A one-time session at hiring does not meet them.

Why practices train every year anyway

• It is what investigators look for. When the Office for Civil Rights looks into a complaint or breach, it asks for proof of training. A dated record for each person, every year, is the simplest proof.
• Threats change every year. Phishing emails, fake invoices and phone scams aimed at dental and medical offices change constantly. Last year’s training does not cover this year’s tricks.
• Insurers and partners ask. Cyber insurance applications and many payer and partner contracts ask whether staff receive security training at least once a year.
• Other California rules are yearly too. SB 553 workplace violence training and OSHA bloodborne pathogens training are required every year, so one yearly training cycle keeps everything on the same calendar.

What is changing

In January 2025, the U.S. Department of Health and Human Services proposed the biggest update to the Security Rule in years. Among other changes, it would make training requirements more specific, including training staff at least once every 12 months. As of October 2026 the update is not final. The federal regulatory agenda now targets July 2027 for a final rule. Practices that already train every year will not need to change their routine.

A simple yearly plan for a dental or medical office

Keep every training record for at least six years. HIPAA requires covered entities to keep required documentation for six years from the date it was created or last in effect.

Not sure how often your other trainings are due? See our renewal chart for California practices, with notes for Texas and other states.

Common questions

Does HIPAA require annual training?

Not in those exact words. The Privacy Rule requires training for new staff within a reasonable time and whenever policies change, and the Security Rule requires an ongoing security awareness program with periodic updates. Yearly training is the standard way practices show they meet both.

How soon must a new employee be trained?

Within a reasonable period after they join. Most practices train new staff in their first week, before they get access to patient information.

How long must we keep HIPAA training records?

Six years. HIPAA requires covered entities to keep required documentation for six years from when it was created or last in effect.

Is the HIPAA Security Rule changing?

A proposed update published in January 2025 would make training more specific, including training at least every 12 months. As of October 2026 it is not final, and the federal regulatory agenda now targets July 2027.

This article is general information, not legal advice. Sources: 45 CFR §164.530 · 45 CFR §164.308 · Proposed Security Rule update (Federal Register, January 6, 2025) · HIPAA Journal: HIPAA updates in 2026.