If you work in behavioral health, you’ve likely felt the ground shifting beneath your feet. Not in a dramatic, headline-grabbing kind of way, but in the quiet, creeping way that risks often sneak into view.
Lately, two issues are beginning to converge in a way that should make every clinician, manager, and system admin pause: the rising number of third-party cybersecurity incidents and the tightening rules around Business Associate Agreements (BAAs). You don’t need to be a compliance officer to feel the pressure. You just need to care about keeping your patients safe and your systems stable.
Why Third-Party Risk Isn’t Just an IT Problem
Let’s start with the everyday reality. Your behavioral health organization probably runs on a patchwork of cloud-based tools, EHR platforms, service vendors, and third-party providers. Most of them are doing good work. Some of them may be indispensable. But every digital connection to a third-party system is also a potential entry point for someone you don’t want inside your network.
It’s not just the headline-making ransomware attacks that put your practice at risk. Small misconfigurations, outdated plugins, shared credentials, or one missed patch on the vendor’s end can open your systems like a false-bottom drawer.
Too many behavioral health professionals still see cybersecurity as an IT-only concern. It’s not. It’s an organization-wide responsibility. Because if your telehealth vendor, billing processor, or cloud storage partner fails to protect PHI, your organization remains accountable under HIPAA. That means you’re the one responding to patients, answering to regulators, and dealing with operational fallout.
Third-party risk in healthcare is not a new issue, but it’s becoming more urgent. Behavioral health organizations are particularly vulnerable because of the sensitive nature of the data they manage, the complexity of their vendor networks, and the resource constraints they often face. Cybercriminals know this. So do regulators.
The BAA Is Getting a Makeover, and You Need to Keep Up
This is where updated Business Associate Agreements come into focus. A BAA is the contract that binds your organization and your vendors to HIPAA compliance standards when protected health information is involved. They’re not optional. And in 2025, they’re getting stricter.
The anticipated HIPAA updates are expected to tighten expectations around vendor accountability, risk-sharing, and breach response. Generic, one-size-fits-all BAAs won’t cut it anymore. Covered entities will likely be required to show detailed documentation of how PHI flows through their vendor ecosystem and prove that their vendors meet updated compliance requirements.
If you’re feeling a little unprepared, you’re not alone. Most behavioral health teams haven’t been trained to critically evaluate a BAA, let alone challenge a vendor on weak terms. But you do know what a strong partnership looks like. Now is the time to apply that same insight to the contracts governing your data.
Ask questions. Push for clarity. Someone in your organization should be able to explain, in plain language, which vendors have access to patient data, how they’re protecting it, and how quickly you’ll be informed if something goes wrong. If those answers don’t come easily, that’s your cue to dig deeper.
This isn’t just about legal risk. It’s about operational stability. The more precise your BAAs are, the more confident your organization can be in the integrity of its vendor relationships.
Getting Practical: What You Can Do Right Now
So what should your team be doing now to prepare for evolving cybersecurity threats and BAA changes?
Start with visibility. Know where your data lives and who touches it. Identify every system that stores, transmits, or processes PHI, especially those managed by third-party vendors. If you send appointment reminders, deliver telehealth sessions, store clinical notes, or manage billing through external platforms, each one deserves review. Make sure your vendors have up-to-date BAAs, and that those agreements reflect current HIPAA requirements.
Then, talk internally. Whether your go-to is the compliance officer, the EHR admin, or the IT lead, open the discussion. Ask how vendor risk is being tracked. Share what you’re seeing. Most importantly, normalize the idea that vendor oversight is a shared responsibility.
If you’re a small team or you wear multiple hats, don’t get discouraged. You don’t need to overhaul your entire security posture in one leap. But you do need to start building habits. Use available tools to track vendor access, document risks, and maintain updated agreements. Set a cadence for regular check-ins. And stay alert to changes in the regulatory environment.
Small, steady improvements will help you avoid big problems down the road.
Xpio Health helps behavioral health organizations turn uncertainty into a plan of action. With deep experience in HIPAA compliance, behavioral health cybersecurity, and vendor risk management, we know how to simplify the complex and help you prepare for what’s next.
If you’re ready to evaluate your third-party risk posture or strengthen your Business Associate Agreements, contact Xpio Health for a consultation.
