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Developing an IT Incident Response Plan for LTC Facilities

July 17, 2025

When something goes wrong in long-term care, we know how to stay calm and act fast. But when the crisis is digital, a ransomware attack or a data breach, do we have the same kind of plan? That's where an incident response plan (IRP) comes in.

A good IRP protects more than just files—it protects people. It ensures that if something suspicious happens, your staff knows who to notify, what to shut down, and how to keep resident care going safely. It also helps meet essential requirements. Many cyber liability insurance policies require facilities to maintain an IRP—and show proof of testing it—before they'll cover breach-related costs.

According to NIST, organizations with a documented and tested incident response plan reduce recovery costs by more than 50% and restore services significantly faster.

So, what does an LTC-specific plan include? At minimum:

  • Clear roles: Who's in charge of communication, investigation, reporting, and IT containment?
  • Communication procedures: How do you notify staff, families, vendors, and regulators?
  • Response checklists: What should nursing do? What should admin shut down?
  • Timeline for reporting: HIPAA requires breach reporting within 60 days, and Ohio mandates immediate notification for serious events.
  • Recovery actions: How do you restore backups and services without compromising care?
  • Post-incident review: What did we learn, and how do we adjust?

Facilities that test their plans regularly—using tabletop exercises—often discover gaps they didn't know existed. Missing contact lists, unclear steps, or outdated tools can all be corrected before a real-world crisis hits. Tabletop drills also provide staff with an opportunity to practice calmly, ask questions, and learn without pressure.

In Ohio, your IRP is often a component of your Written Information Security Program (WISP)—a master document that outlines your entire data protection approach. If you have a WISP and use it consistently, it can even serve as a legal defense in civil litigation following a data breach. It shows you took steps to protect resident data and acted in good faith.

A skilled nursing facility near Cincinnati created its IRP with help from its MSP and compliance officer. Twice a year, they practiced cyber drills and updated staff roles. When a real phishing attack targeted their business office, their training kicked in. IT was alerted within minutes, the email server was secured, and no resident data was lost.

"Plans are worthless, but planning is everything." - Dwight D. Eisenhower (quoted in HHS Cybersecurity Guidelines)

Contrast that with a memory care facility in Northeast Ohio. When an employee's laptop was stolen from a car, no one knew who to notify. The device wasn't encrypted. It took days to realize the extent of the data exposure—long enough for resident info to hit the dark web. The result? A $70,000 OCR fine and a painful audit.

"You can't predict, but you can prepare." - Atul Gawande

Here's the hard truth: incidents will happen. But the damage depends on how prepared you are.

So if a breach happened at 2 AM tonight, would your staff know what to do?

Learn more about Affiliated's healthcare-specific IT Support and Services in Columbus and the Central Ohio areas by clicking here.