HIPAA policies for solo therapists in California

What federal law requires of every California practice

The HIPAA Security Rule (45 CFR § 164.316) requires written policies covering ten domains: designated privacy and security officials, risk analysis, workforce sanctions, access management, audit controls, contingency planning, breach notification, business associate agreements, workforce training, and device and media security. Policies must be retained for six years, carry effective dates, and be updated when your practice or the rules change.

What California adds

California's Confidentiality of Medical Information Act (CMIA) applies alongside HIPAA and is in several respects stricter — including a private right of action, meaning patients can sue directly for improper disclosure. California therapists should make sure their policies reference CMIA obligations, not just HIPAA.

The practical standard: adopted, dated, versioned

Regulators don't ask whether you own policy documents — they ask for the policy in effect on a given date, with its adoption record and revision history. A static template pack can't answer that. A policy set with attestations, effective dates, and version history can.