HIPAA Contingency Plan Template

Download a HIPAA contingency plan template for small medical clinics. Covers all five required components of 45 CFR §164.308(a)(7): data backup, disaster recovery, emergency mode operations, testing, and applications criticality analysis.

Short answer

A written HIPAA contingency plan template that satisfies all five required and addressable implementation specifications of 45 CFR §164.308(a)(7), with step-by-step completion guidance for small clinic Security Officers.

What is inside

All five §164.308(a)(7) components: data backup plan, disaster recovery plan, emergency mode operations plan, testing and revision procedures, and applications and data criticality analysis
A criticality analysis worksheet to identify which systems must be recovered first
Backup verification checklist with weekly and monthly confirmation steps
Emergency mode operations procedures for maintaining PHI protection when primary systems are unavailable
An annual test and revision log to document that the plan is current and has been exercised

We publish the same practical templates and decision tools that clinics use to structure recurring HIPAA work. No enterprise gate. No resource-library gimmicks. Just practical material delivered quickly.

Editorial details

Written by: Angel Campa

Reviewed by: PHIGuard Compliance Research

Updated: April 23, 2026

Best next step: Open the matching product path

Verified: April 23, 2026

Sources

Download the PDF

A written HIPAA contingency plan covering data backup, disaster recovery, and emergency operations — ready for your Security Officer to complete

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Questions

Is a HIPAA contingency plan the same as a disaster recovery plan?

The contingency plan required by 45 CFR §164.308(a)(7) is broader than a typical IT disaster recovery plan. It includes data backup, disaster recovery, and emergency mode operations — how you continue to protect PHI and operate your clinic when systems are unavailable — as well as testing and criticality analysis.

How often does the contingency plan need to be tested?

45 CFR §164.308(a)(7)(ii)(D) requires testing and revision procedures as an addressable specification. Most Security Officers conduct at least an annual test, including a tabletop exercise and a verification of backup restoration. Document the test date, participants, and findings.

What counts as emergency mode operations under HIPAA?

Emergency mode operations refers to maintaining essential access to PHI and continuing required security protections during a system outage, natural disaster, or other emergency. Your plan must specify which staff have emergency access, which PHI systems are critical, and what manual procedures replace automated controls during the outage.

What happens to the contingency plan if we change EHR vendors?

Any change to the systems holding ePHI — a new EHR, a cloud migration, a backup vendor change — requires a review and update of the contingency plan. The applications and data criticality analysis and the data backup plan sections will need to be revised to reflect the new environment.