Two-Factor Authentication (2FA)
What is Two-Factor Authentication?
Two-Factor Authentication (2FA) is a security process that requires two different forms of verification before granting access to ePHI. Typical factors include a password (which the user is expected to know) and a security token or phone code (which the user is expected to have access to).
By combining the two factors, 2FA significantly reduces the risk of unauthorized access.
HIPAA Requirements for 2FA
HIPAA does not explicitly mandate 2FA, yet. However, the Security Rule requires “person or entity authentication” to verify that those seeking access to ePHI are who they claim to be. OCR has repeatedly highlighted 2FA as a reasonable and appropriate safeguard, and proposed updates to the Security Rule will make 2FA or MFA mandatory in certain cases.
Why 2FA Matters
By enabling 2FA, organizations can enhance their protection of ePHI. Employers can ensure that data remains safe and uncompromised even if the password gets stolen. 2FA also defends systems against phishing attacks and helps meet OCR expectations for strong authentication controls.
Best Practices for 2FA
- Use authenticator apps or hardware tokens instead of SMS: While SMS-based 2FA is better than relying solely on passwords, it has known vulnerabilities such as SIM swapping, phishing, and interception. Healthcare organizations should prioritize the use of authenticator apps which generate time-based one-time codes that cannot be easily intercepted.
- Require 2FA for all remote and privileged system access: Not all systems carry the same level of risk, but remote access and privileged accounts (such as administrators or super-users) are prime targets for attackers. HIPAA’s Security Rule requires ‘reasonable and appropriate’ measures to protect against unauthorized access, and enforcing 2FA at these high-risk access points is considered industry best practice.
- Regularly test authentication workflows: A 2FA system is only effective if it works consistently and securely. Healthcare organizations should conduct routine testing of authentication workflows to ensure that codes are being generated correctly, tokens are functioning, and backup methods (such as recovery codes) do not create new vulnerabilities.
- Train staff on phishing risks targeting 2FA bypass: Even the strongest technical safeguards can fail if employees are not properly trained. Attackers frequently attempt to bypass 2FA by tricking users into providing authentication codes through phishing emails, fake login portals, or phone scams. Healthcare staff should undergo regular HIPAA compliance training that includes modules on recognizing phishing attempts, avoiding rushed logins, and reporting suspicious activity.
Related Terms
Two Factor Authentication
End-to-End Encryption
Privacy Policy