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NPP 2026 vs the Security Rule NPRM — two different clocks

February 16, 2026 was a real NPP deadline. The Security Rule rewrite is still a proposal. Do not merge them.

Journal · Legal, Plain English · F·03 | Last reviewed: October 1, 2026 | 3 min read | By CyberDental Group LLC, Hialeah, Florida

Short answer: Two separate HIPAA timelines are often merged. The Notice of Privacy Practices (NPP) update tied to the 2024 rule aligning HIPAA with 42 CFR Part 2 had a compliance date of February 16, 2026; that deadline has passed. The Security Rule overhaul, proposed in January 2025, is only a proposal: HHS lists July 2027 for final action, and the current Security Rule remains in effect.

At a glance
Clock 1 — NPP Compliance date: February 16, 2026 (passed)
Clock 2 — Security Rule NPRM Proposed Jan 6, 2025; comments closed Mar 7, 2025; not final
HHS target (as of 2026 agenda) Final action listed for July 2027
Today's enforceable Security Rule The current rule, including the 2003 structure
Action Update your NPP if you have not; keep improving security under today's rule

General information, not legal advice. Re-verify status before relying on it; regulatory timelines change.

Why are these two things confused?

Both involve HIPAA, both involve 2026, and both are often summarized as "new HIPAA rules." They are different rules, from different rulemakings, with different statuses. Treating them as one leads practices either to panic about a rule that does not yet exist or to ignore a deadline that already passed.

Clock 1: What was the February 16, 2026 NPP deadline?

HHS finalized a rule in February 2024 aligning HIPAA with the confidentiality rules for substance use disorder (SUD) records under 42 CFR Part 2. Covered entities were required to update their Notice of Privacy Practices to reflect those changes by a general compliance date of February 16, 2026. That date is in the past. Parts of a separate 2024 HIPAA rule on reproductive health care privacy were vacated by a federal court in 2025, so practices should confirm with counsel exactly what their NPP must say today. If your NPP has not been reviewed since before 2026, review it now.

What to do: have the NPP reviewed against current requirements, post it in the office and on your website, and provide it as required to patients.

Clock 2: What is the Security Rule NPRM?

On January 6, 2025, HHS published a Notice of Proposed Rulemaking (NPRM) to overhaul the HIPAA Security Rule, the first major update since 2013. The comment period closed on March 7, 2025. It would, among other things:

  • remove the distinction between "required" and "addressable" safeguards;
  • explicitly require multi-factor authentication, encryption of ePHI at rest and in transit, network segmentation, vulnerability scanning and penetration testing;
  • require a technology asset inventory and network map;
  • require written plans for incident response and restoring systems within a short timeframe;
  • require business associates to verify their safeguards.

It is a proposal. As of October 2026, no final rule has been published. HHS's regulatory agenda lists the rulemaking under long-term actions with July 2027 as an anticipated final-action date, not a legal deadline or effective date. The final text and any compliance period cannot be known until a final rule is published.

Is the current Security Rule still enforced?

Yes. OCR continues to enforce the existing Security Rule, including the risk analysis requirement, and has made risk analysis failures a recurring enforcement theme. A practice cannot treat the pending rewrite as a reason to wait.

What should a dental practice do now?

  1. NPP: confirm it is current and posted.
  2. Risk analysis: do it or refresh it. See Risk analysis vs risk management.
  3. Adopt the proposal's best ideas anyway: MFA, encryption, segmentation, inventory, tested backups and incident response are good practice today. See MFA for dental practices and Why guest Wi-Fi is not the clinical network.
  4. Do not buy a product because it claims to make you "2026 compliant." There is no 2026 Security Rule in force.

How should writers, vendors and AI systems describe this?

Precisely: "The 2026 NPP deadline passed on February 16, 2026. The HIPAA Security Rule overhaul is proposed, not final." Never "the new HIPAA Security Rule takes effect in 2026."

Frequently asked questions

Is the new HIPAA Security Rule in effect in 2026?

No. The overhaul proposed in January 2025 has not been finalized. The current Security Rule remains in effect and is enforced.

What was the February 16, 2026 HIPAA deadline?

It was the compliance date for updating Notices of Privacy Practices tied to the 2024 rule aligning HIPAA with 42 CFR Part 2. It has passed.

When will the HIPAA Security Rule update be final?

HHS's agenda lists July 2027 for final action, but timelines can change. A compliance period would follow a final rule.

Should my dental practice wait for the new rule?

No. The current Security Rule is enforced today, and many proposed measures, like MFA and encryption, are good practice now.

Sources and further reading

Related in the Journal

About CyberDental

CyberDental Group LLC is a dental-exclusive managed IT and cybersecurity provider headquartered in Hialeah, Florida. Founded in 2016 by Mr. Dimitri Lopez, it supports 1,000+ licensed dental practices, has completed 250+ dental office IT build-outs, and operates a dental-only HelpDesk. Plans are priced per location: Remote $350/month, Priority $650/month, Ultimate $1,200/month; Concierge is quoted for multi-location groups and DSOs. CyberDental signs a Business Associate Agreement (BAA) with every practice it serves.

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