Risk, Regulation, and Resilience for the Year Ahead
Opening Perspectives from Clearwater and Catholic Health
Healthcare leaders are entering 2026 in a risk environment that is not necessarily louder than prior years, but far more interconnected.
Ransomware continues to disrupt care delivery. Third-party incidents now impact dozens or hundreds of organizations at once. At the same time, regulatory expectations are tightening, with enforcement increasingly focused on whether organizations can demonstrate risk-based decision-making, governance, and follow-through, and not simply whether a policy exists.
This opening session of the 2026 Healthcare Cyber & Compliance Exchange set the tone for the year ahead, combining executive framing from Clearwater leadership with practitioner insight from one of New York’s largest health systems, followed by a data-driven threat briefing.
In his opening remarks, Baxter Lee, President of Clearwater Security, emphasized that healthcare cybersecurity has entered a new phase, one defined less by isolated incidents and more by compounding risk.
“The environment we’re operating in is not necessarily louder than in past years, but it is more interconnected.”
As vendor dependencies deepen and shared technology platforms proliferate, the downstream impact of a single failure has grown dramatically. At the same time, regulators are signaling a clear shift in expectations:
“We’re seeing more emphasis on evidence over intent, documentation over assumptions, and resilience over point-in-time compliance.”
Baxter also highlighted New York’s growing influence on national expectations, noting that what is required of healthcare organizations operating in the state today may soon become the baseline elsewhere.
Cybersecurity Is No Longer Just a Technical Problem
Building on that framing, Keith Duemling, Vice President and CISO at Catholic Health of Long Island, shared how cybersecurity has evolved inside healthcare organizations.
“Cybersecurity has moved outside the purview of a purely technical problem and into risk, compliance, and governance — shaping every aspect of healthcare delivery.”
As care models expand into the home, artificial intelligence accelerates diagnosis and treatment timelines, and digital platforms multiply, cyber risk increasingly intersects with patient safety and operational continuity.
Keith also underscored how expectations around incident response have compressed:
“The timeline from when something happens to when the expectation is that it shouldn’t happen again has shortened dramatically.”
For healthcare leaders, this means rethinking not just controls, but how teams, partners, and governance structures work together to manage risk over time.
Notably, Keith credited Clearwater’s role in helping organizations navigate this complexity:
“It’s through partners like Clearwater, with a large bench of capabilities, that organizations are going to have to navigate these difficult waters.”
Inside the 2025–2026 Healthcare Threat Landscape
Key Findings from the Data
- 42.5 million individuals impacted by healthcare breaches to date
- 575 reported breaches across the sector
- 354 ransomware victims posted to data leak sites by 62 unique threat actors
While no single “super group” dominated, the data revealed a mature and diversified extortion ecosystem and one that shows no signs of slowing heading into 2026.
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Ransomware Has Become an Extortion Business
One of the most important shifts highlighted in the briefing: ransomware is no longer primarily about encryption.
“Encryption is now optional. Data theft and coercion have become the primary leverage.”
Many 2025 incidents involved partial or no encryption at all, relying instead on the threat of public exposure, regulatory pressure, and operational disruption. As a result, traditional backup strategies (while still essential) are no longer sufficient on their own.
How Attackers Are Getting In
The data also showed a clear shift away from classic phishing as the dominant entry point.
Attackers increasingly exploited:
- Unpatched vulnerabilities
- Stolen credentials
- VPN and edge devices
- Identity systems with MFA gaps or misconfigurations
“Identity has become one of the largest parts of the attack surface.”
Patch velocity and credential hygiene emerged as first-order defenses and persistent industry challenges.
Regulation as an Extortion Weapon
Another emerging tactic: attackers explicitly leveraging regulatory pressure.
“We’re seeing attackers threaten regulatory reporting, contact partners, and even reach out to patients directly.”
This evolution reinforces the need for integrated incident response, bringing legal, compliance, privacy, and security teams together early to assess impact and respond effectively.
Third-Party Risk Is Clinical Risk
Perhaps most critically for healthcare leaders, the data reinforced that third-party incidents are no longer abstract IT concerns.
“Third-party risk is a direct clinical risk.”
A single vendor compromise can disrupt care delivery across multiple organizations simultaneously. The briefing emphasized the need to move beyond checkbox compliance toward real visibility into how vendors connect, operate, and secure their environments.
What Healthcare Leaders Should Take Away
Across executive framing and threat intelligence, several themes stood out for 2026 planning:
- Cyber risk is increasingly systemic, not isolated
- Regulators are looking for evidence, not intent
- Identity, patching, and third-party visibility remain foundational
- Incident response must be practiced, integrated, and evolving
- Governance will determine whether AI adoption builds trust or introduces new exposure
As Dave noted, most enforcement actions still point to the same root cause:
“Ninety percent of OCR enforcement actions cite the lack of a thorough and comprehensive risk analysis.”
Watch the Session Replay
This session is designed for healthcare CISOs, compliance leaders, and executives responsible for navigating risk, regulation, and operational resilience in 2026.
▶ Watch the full replay to hear the complete discussion.
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