HITRUST vs. SOC 2 + HITRUST: Which Should You Choose?

As organizations face pressure to obtain third-party validation demonstrating their effective cybersecurity and risk management practices, they may wonder which  compliance approach is best to pursue. HITRUST Certification is a globally recognized program that validates an organization’s compliance with the HITRUST Common Security Framework (CSF). An alternative to obtaining a HITRUST CSF Certification is the SOC 2 + HITRUST report, which serves as a collaboration between HITRUST and the AICPA.  

Though HITRUST CSF Certification and SOC 2 + HITRUST reports have notable differences, they share an intended purpose of being valuable tools used to illustrate an organization’s robust security and privacy practices for protected health information (PHI). In this article, we’ll define the HITRUST Certification and SOC 2 + HITRUST report, provide a thorough comparison of their key characteristics, and share tips to help you determine which approach is right for your organization. This way, you'll be well informed and can proceed with confidence on your compliance journey.

What is a HITRUST Certification? 

The HITRUST Certification is a widely recognized security and privacy standard that helps organizations demonstrate a comprehensive and consistent implementation of risk management and compliance controls. Developed and governed by the Health Information Trust Alliance in 2007, HITRUST CSF certification integrates and harmonizes control requirements from numerous standards and regulations, including HIPAA, NIST SP 800-53, ISO/IEC 27001, PCI DSS, and others, creating a single, prescriptive framework for organizations to follow. 

HITRUST offers three levels of assessment: e1, i1, and r2, each designed to align with an organization’s risk profile and assurance needs. The e1 assessment is the entry-level option, providing a foundational evaluation of basic cybersecurity hygiene ideal for organizations with low-risk environments that need to demonstrate conformance to essential cybersecurity practices. The i1 assessment, or Implemented 1-year assessment, focuses on the implementation of controls that address emerging threats and industry best practices, intended for organizations seeking a moderate level of assurance without the full rigor of the r2. 

The r2 assessment, HITRUST’s most rigorous and comprehensive offering, evaluates control implementation across 19 domains, scoring each requirement based on a maturity model that includes policy, procedure, implementation, measurement, and managed practices. The r2 Certification is tailored for organizations operating in highly regulated industries or those managing sensitive data and complex risk environments. 

The certification process typically begins with a scoping exercise to determine the systems, services, and data in scope. Many organizations choose to perform a readiness assessment to identify and remediate gaps before undergoing the validated assessment. Once submitted, HITRUST performs an independent quality assurance review to validate evidence and scoring. For organizations seeking a scalable and trustworthy approach to demonstrating security and privacy compliance, the HITRUST assessment portfolio offers a highly structured, industry-vetted path to assurance. 

What is the SOC 2 + HITRUST Report? 

The SOC 2 + HITRUST Report is a combined attestation that evaluates an organization’s controls under both the AICPA’s SOC 2 Trust Services Criteria and the HITRUST CSF framework. This dual-purpose report is designed for organizations who want to streamline their compliance efforts and provide a single, comprehensive assurance report to stakeholders. The SOC 2 framework, established by the American Institute of Certified Public Accountants (AICPA) in 2011, focuses on evaluating internal controls relevant to security, availability, processing integrity, confidentiality, and privacy. Meanwhile, the HITRUST CSF brings a detailed and prescriptive set of controls that align with healthcare and other high-compliance industries. 

During the SOC 2 + HITRUST unified audit process, the 150 HITRUST CSF control requirements are mapped to the applicable Trust Services Criteria to ensure consistency in the evaluation. The resulting report includes the auditor’s opinion on whether controls were suitably designed and operating effectively either over a specified review period (Type 2) or at a point in time (Type 1). Unlike the HITRUST Certification, however, this assessment results in an attestation report rather than a certification badge.

This combined approach is ideal for organizations who want to align with HITRUST’s rigorous control requirements without going through the full certification process. It provides a valuable middle ground, offering assurance to clients and partners across industries, while reducing the need for multiple separate audits. The SOC 2 + HITRUST Report is particularly attractive to organizations in the healthcare tech space, SaaS companies, and business associates looking to prove compliance and security readiness to a broad audience. 

HITRUST vs. SOC 2 + HITRUST: Similarities and Differences 

Each report utilizes the HITRUST CSF as the base framework for addressing security and privacy practices. While SOC 2 does have its specific criteria for each of the Trust Services Principles (TSP) of security, availability, processing integrity, and confidentiality, HITRUST and the AICPA have mapped the CSF controls to these criteria (with the exception of the privacy principle which to date, has not been mapped).  

However, since HITRUST has different level requirements for controls based on scoping factors for organizations, it is still critical for organizations undergoing a SOC 2 + HITRUST to declare the specific organization, system, and regulatory factors that determine the true scope of HITRUST requirements that must be tested for SOC 2 criteria. The factors for one organization's examination may only require Level 1 implementation, whereas the factors for another organization could require up to Level 3 implementation. 

Although the same scope of controls is tested for both a HITRUST CSF and SOC 2 examination, the method in which the controls are examined is different. HITRUST requires a maturity rating to be established for each control requirement, whereas SOC 2 + HITRUST only tests for the design of the control for Type 1 and both the design and operating effectiveness of the control for Type 2 engagements. HITRUST also allows for Corrective Action Plans (CAPs) to help with the achievement of certification, whereas SOC 2 + HITRUST does not identify CAPs and only reports the control deviations that are determined through testing. 

Both approaches require an independent third-party examination performed by a qualified professional, such as Schellman. A SOC 2 report requires the services of a CPA, and HITRUST CSF Certification requires the services of a HITRUST approved CSF Assessor Organization. A third reporting option combines the two separate SOC 2 + HITRUST and HITRUST certification reports into a single SOC 2 + HITRUST + HITRUST Certification report. This reporting option merely requires that both types of examinations be performed with the results of the HITRUST CSF Certification placed into the unaudited section of the SOC 2 report. 

The frequency and scope of examinations differ across HITRUST assessment types and SOC 2 + HITRUST reports. The certification for e1 and i1 is valid for one year, meaning a full assessment is required annually, however r2 certification is valid for two years with a full assessment performed in Year 1. Then, in Year 2, an interim review is conducted where the CSF Assessor tests a sample of at least one control from each of the 19 HITRUST domains and submits the results to HITRUST to maintain certification. In contrast, SOC 2 + HITRUST reports require a full-scope examination for each reporting period, with no interim testing option—every examination must include testing of all applicable controls. 

A Comparison of the SOC 2 and HITRUST Reporting Options

The table below compares the different SOC 2 and HITRUST reporting options and their key characteristics. When considering which the type of report to prepare for clients, prospects, or providers, ensure that your organization selects a CPA firm or HITRUST Assessor who understands the distinct differences and who strategically partners with your organization to provide the service and expertise necessary for comprehensive reporting. 

HITRUST vs. SOC 2 + HITRUST: Which is Right for Your Organization? 

When deciding between pursuing HITRUST Certification or a SOC 2 + HITRUST Report, you should begin by evaluating your organization's regulatory obligations, industry expectations, and risk posture. If you operate in a highly regulated environment and need to demonstrate detailed control implementation and risk management maturity, the HITRUST r2 Certification may be the right choice due to its depth, structure, and prescriptive nature. Alternatively, if your primary goal is to meet broad customer assurance demands or satisfy multiple compliance objectives in a single report, a SOC 2 + HITRUST Report may offer greater flexibility and efficiency. 

As best practice, start with a thorough internal risk assessment to better understand your organization’s current compliance maturity and strategic goals. Stakeholder alignment is also essential for success. Engage compliance, legal, and customer-facing teams early in the process to identify specific requirements from regulators, partners, or clients. Consulting with a HITRUST Authorized External Assessor or a CPA firm with HITRUST experience can further help guide the decision based on the size, complexity, and maturity of your security program. 

Now that you’re more familiar with your options, hopefully you feel better prepared to proceed with your compliance journey. Whether you choose to pursue HITRUST Certification, a SOC 2 + HITRUST Report, an alternative compliance assessment, or simply want to learn more about the requirements and processes involved, Schellman can help. Contact us today and we’ll get back to you shortly.  

In the meantime, discover other helpful compliance tips and insights in these additional resources:  

• The Benefits of Consolidating Compliance Services with a Single Provider
• What You Should Know About HITRUST CSF v11.3 
• The HITRUST AI Risk Management Assessment: An Introductory FAQ 
• 5 Steps to Prepare for SOC 2 Examination Success
  

1 The CPA firm must have a valid license to utilize the HITRUST CSF. 

2 Year 2 of a HITRUST Certification requires an annual review to be performed by the CSF Assessor that consists of testing a minimum sample of one control from each domain.