As a vCISO for small and medium hospitals, I’ve learned one lesson: don’t start with technology, start with governance. This shift often determines whether a hospital’s compliance program succeeds or struggles. 

It’s tempting to assume that buying tools or updating policies will check the box. But regulations today—whether HIPAA, NY §405.46, or others—are becoming more prescriptive. Hospitals must maintain policies that cover specific areas, conduct and document annual risk assessments, and ensure governing-body oversight. I’ve seen organizations rush into new tools and templates, only to discover later they lacked the cross-functional structure to review risks, set priorities, and enforce accountability. 

The truth is, compliance frameworks differ, but the challenge is the same: without governance, hospitals risk producing policies that look good on paper but fail in practice, leaving them vulnerable to findings, penalties, and, most importantly, threats to patient safety. 

My recommendation is straightforward: establish or strengthen your cybersecurity governance committee now. Include executive leadership, compliance, IT, and clinical voices at the same table. Use that group to map your current program against required areas, assign accountable owners, and track progress consistently.