Understanding HIPAA Requirements for Paper PHI

Key Takeaway

HIPAA requires covered entities to protect paper PHI with reasonable safeguards, minimum necessary access, and secure disposal practices. Learn the key requirements for paper records, the most common paper PHI mistakes, and how digital forms can support safer, more efficient workflows.

Table of Contents

• Introduction
• Why Many Practices Stick With Paper
• HIPAA Requirements For Paper Form Storage
• Common Mistakes With Paper PHI
• What Are The Benefits of Digital Forms?
• Paper vs. Digital Risks
• Form Vessel Supports an Easy Transition
• Try It Today

Disclaimer: This article is for informational purposes only and does not constitute legal advice. Always consult a qualified attorney or compliance professional when interpreting HIPAA regulations.

Quality tools are essential for effective medical care. From sharp scalpels for surgery to a simple reflex hammer for checkups and everything in between, the tools must be made to support the job. One tool that many overlook in healthcare is forms. There are patient intake forms that ensure providers have the necessary information to provide quality care, as well as administrative forms that work behind the scenes to ensure the whole operation runs smoothly.

Heading into 2026, it can be easy to assume that everything is stored online. Cloud storage solutions are everywhere. They make it incredibly easy to facilitate quick access to important documents. However, many healthcare organizations are still doing it the old-fashioned way. Forms live on paper and hang out in locked filing cabinets. This blog will evaluate why that is the case for so many providers, what security requirements come with physical form storage, the benefits of digitizing forms, and how organizations can make the switch seamlessly.

Why Many Practices Stick With Paper

It’s easy to conceptualize the benefits of digital forms because we interact with digital solutions every day. Most people use some element of Google Drive or iCloud at least once a day because it simply makes life easier. So why not bring that efficiency into the healthcare world?

The simple answer is that it’s uncomfortable. Temporary discomfort in the face of long-term gains is fine in the gym, but it can be frightening in the medical world. Simple clerical errors can have serious effects. A patient might receive the wrong medication. The wrong test may be administered. In extreme cases, surgeries can be seriously complicated by communication and documentation errors. The list of things that could go wrong is endless, and implementing a new system takes time, effort, and training to ensure that it is safe to use.

When that is the case, it is almost always safer and easier to stick with what is comfortable. Paper documentation has been around forever in the medical world, and it has always seemed “good enough.”

Of course, negative patient outcomes are the most severe consequences. However, there is also often cost implications, staff resistance, limited IT support, and other factors that can contribute to the hesitation. With all these considerations, it’s easy to wonder why an organization would switch away from an already functional solution when there are real risks that come with it?

HIPAA Requirements For Paper Form Storage

Paper form solutions are often comfortable for many practices, but they also come with real security requirements. HIPAA was implemented in 1996 and meant to safeguard PHI that mostly existed in a physical format at the time. It wasn’t until the 2003 Security Rule was created that there were more concrete protections for digital storage options. These were further strengthened by the HITECH and Omnibus Rules. Although HIPAA has been altered to provide more robust safeguards for electronic PHI, the rules for paper PHI are still present and strong.

The Minimum Necessary Standard

The principle of “minimum necessary” is a central aspect for all of HIPAA. It applies to PHI in all forms.

Covered entities and their business associates must “take reasonable steps to limit the use or disclosure of, and requests for, protected health information to the minimum necessary to accomplish the intended purpose.”

In practice, it’s fairly simple. PHI should only be accessed by those who need it. A nurse providing care? They probably need access. A member of the janitorial staff? They’re still important to the whole operation, but they don’t need access to sensitive information.

Access Controls

One of the main ways that the minimum necessary standard is enforced is through access controls. The privacy rule does not necessarily mention specifics, but in the event of an audit, a covered entity needs to prove that they implemented reasonable safeguards. For smaller organizations, a simple locked cabinet might suffice. For larger organizations, an OCR auditor might note that it’s reasonable to expect a storage room with security personnel or even offsite secured storage solutions.

The requirements are up to interpretation, so the best thing that covered entities can do is implement as many reasonable safeguards as possible. Depending on how much PHI is retained, this can be an extensive process.

Destruction Requirements

HIPAA does not disappear just because PHI is no longer needed. There are also safeguards that govern the destruction of PHI. As with many HIPAA requirements, a specific method of disposal is not outlined. However, covered entities cannot simply throw old PHI in publicly accessible dumpsters or trash containers. PHI also cannot be disposed of in private trash receptacles that can easily be accessed by non-authorized persons (like the aforementioned janitorial staff).

When conducting security reviews, covered entities must examine their method of disposal and implement safeguards they deem reasonable for their specific situation. Some of the most common options are shredding, burning, pulping, or pulverizing records. That list is not exhaustive or fully safe, as the circumstances also dictate the level of care required and depend on the level of sensitivity of the PHI in question.

Common Mistakes With Paper PHI

It’s easy to think that most PHI breaches happen because of bad actors with malicious intent. Locked storage and effective destruction methods are great for managing this. However, oftentimes it’s minor accidents that can lead to incidents. Paper documents might get left in printers, on desks, or misfiled in non-secure locations. Sometimes providers have even less control because a patient may leave their paperwork on a clipboard in a public area or an error can happen when documents are being transported from one place to another.

Whenever these accidents happen, it’s simply human nature that unauthorized viewers might grab PHI and start reading to understand what the document is and where it belongs. By the time they realize it’s PHI, it’s already too late.

What Are The Benefits of Digital Forms?

Digital form solutions can help simplify many of the compliance requirements. It’s important to understand that making this transition does not eliminate requirements, it simply changes them. However, these changes can often be more manageable for teams of all sizes if their digital form solution is designed to support HIPAA compliance.

Access control is easier because the requirements likely won’t scale as much with an organizations size and amount of stored PHI. Rather than needing a locked facility with security, organizations can operate with a secure workstation and password protected accounts. These help implement the minimum necessary principle because only staff who need access should be issued these accounts.

Destruction is also made easier if the form software is designed to properly eliminate data. Rather than worrying about shredding or burning PHI (or paying a third-party vendor to do it), users can simply click delete on the records that are no longer needed.

Additionally, a quality digital form software should provide audit logs that make administrative tasks much easier. In the event of a breach, proper logging should allow administrators to pinpoint exactly when the improper access occurred and whose account was responsible. This is much more precise than the audit process for paper PHI that generally requires manual reviews and self-reported time logs or estimates.

Paper vs. Digital Risks

As previously stated, digital forms do not eliminate risks and requirements, they just change them. That’s why it’s important for organizations to understand both options to better make an informed choice.

Paper

Pros

• Established workflows
• Minimal training
• Some patients may prefer non-technical solutions
• Confirmation of destruction is more visible

Cons

• Slow
• Bulky
• Security requirements may scale exponentially
• Destruction is not always straightforward
• Improper access is more difficult to monitor

Digital

Pros

• Fast
• Convenient for most patients
• Easy transfer into Electronic Health Records (EHRs)
• Simplified Access Control
• Precision Auditing Tools

Cons

• May require additional training
• Compliance has technical complexity
• Proper destruction must follow specific requirements for digital standards

Regardless of the chosen solution, it’s important to understand that there is no instant fix for HIPAA compliance. Both options carry their own implications and must be properly configured and documented according to HIPAA’s requirements.

Form Vessel Supports an Easy Transition

Form Vessel is designed to make it easier for covered entities to transfer to a digital form solution. The drag and drop builder is powerful and intuitive. It supports multiple levels of users. Those who want a simple experience can build a form with their required elements and quickly publish it. Even without heavy design work, the form will be functional and look professional. Those who want their forms to be more fully integrated with their practice’s identity will have a suite of design controls for every element they place.

Your team can get started quick too. Once a user is added, they’ll receive an email notification that directs them to create their own password protected account. It’s easy to find the submission viewer in the navigation bar after that. If they don’t want to bother with the interface, there is also the option to receive an email after every submission that allows them to login to their account and be brought directly to the right place.

Forms are easy to build, easier to implement (whether on a website or through a direct link), and your team won’t have to worry about an extensive training process. Plus, Form Vessel was specifically built for healthcare, so HIPAA compliance is a core feature. It’s still not a magic fix for compliance, but our software has been developed with the technical safeguards in mind so that providers can trust that it is a solid cog in their compliance machine.

Try It Today

If you’ve been on the fence about switching your practice to digital forms, you’re not alone. It can seem like a gargantuan task, and it can carry real risks if not done properly. Form Vessel is designed to support this transition with intuitive design controls and HIPAA-aligned safeguards that can help you finally enjoy the benefits of modern, digital workflows.