Windows XP Is No Longer HIPAA Compliant

For those of you who missed it, thousands in healthcare are now out of compliance with HIPAA thanks to Microsoft’s decision to stop supporting Windows XP. I wrote about the details of Windows XP and HIPAA compliance previously. Microsoft stopped supporting the Windows XP operating system on April 8, 2014 and as Mac McMillan says in the linked post, OCR has been clear that unsupported systems are not HIPAA compliant.

I asked Dell if they had any numbers on the number of PCs out there that are still running XP. Here was their response (Note: These are general numbers and not healthcare specific)

The latest data I’ve seen shows that around 20-25% of PCs are still running XP (number vary depending on the publication). But most of those are consumer devices or very small businesses. Larger organizations seem to be complete, on track to completing by April, or have already engaged Dell (or competitor) to migrate them.

Dell also told me that globally, they have helped more than 450 customers (exact count is 471) with Windows 7 migration and automated deployment.

I’m not sure I agree with their assessment that the larger organizations have pretty much all upgraded beyond Windows XP. I agree that they’re more likely to have upgraded, but I’m sure there’s still plenty of Windows XP in large hospital systems across the nation. I’d love to hear from readers to see if they agree or disagree with this assertion.

I’ve heard some people make some cases for why Windows XP might not be considered a HIPAA violation if it was a standalone system that’s not connected to a network or if it was in a highly controlled and constrained use case. Some medical devices that still require Windows XP might force institutions to deal with HIPAA like this. However, I think that’s a risky situation to be in and may or may not pass the audit or other legal challenges.

I think you’re a brave (or stupid if you prefer) soul to still be running Windows XP in healthcare. Certainly there wasn’t a big disaster that occurred on April 8th when Windows XP was no longer supported. However, I’d hate to be your organization if you have Windows XP and get a HIPAA audit.

If you haven’t updated your HIPAA policies lately, you may want to do that along with updating Windows XP. This whitepaper called “HIPAA Compliance: Six Reality Checks” is a good place to start. Remember also that once an auditor finds one violation (like Windows XP), then they start digging for even more. It’s a bit like a shark that smells (or however they sense) blood in the water. They get hungry for more. I don’t know anyone that enjoys a HIPAA auditor, let alone one that really starts digging for problems.

About the author

John Lynn

John Lynn

John Lynn is the Founder of, a network of leading Healthcare IT resources. The flagship blog, Healthcare IT Today, contains over 13,000 articles with over half of the articles written by John. These EMR and Healthcare IT related articles have been viewed over 20 million times.

John manages Healthcare IT Central, the leading career Health IT job board. He also organizes the first of its kind conference and community focused on healthcare marketing, Healthcare and IT Marketing Conference, and a healthcare IT conference,, focused on practical healthcare IT innovation. John is an advisor to multiple healthcare IT companies. John is highly involved in social media, and in addition to his blogs can be found on Twitter: @techguy.