One of the most common calls we get at Agency starts the same way: "We just got a procurement requirement from a hospital system, and they need SOC 2 -- how fast can we make this happen?" The answer, based on our experience helping healthtech companies through exactly this scenario, is ninety days -- if you already have a HIPAA program in place and you make the right decisions about scope, platform, and auditor from day one.
When a healthtech startup receives a request from a major hospital system or health insurer that includes SOC 2 compliance as a procurement requirement, the timeline pressure can be intense -- enterprise healthcare buyers often have specific procurement cycles, and delays in compliance can mean losing the deal or waiting another quarter to re-enter the evaluation process. This case study examines how we helped a representative healthtech startup achieve SOC 2 Type II compliance in ninety days, an accelerated timeline that required deliberate trade-offs, strategic reuse of existing HIPAA controls, careful platform and auditor selection optimized for speed, and focused execution by a small team. The ninety-day timeline is aggressive but achievable for healthtech companies that already have a baseline of security controls from HIPAA compliance -- the regulatory overlap between HIPAA and SOC 2 provides a significant head start that companies in non-regulated industries do not have. This case study covers the specific approach taken, the HIPAA controls that transferred directly to SOC 2, the platform and auditor decisions that maximized speed, the trade-offs that were made, and the lessons that other healthtech companies under similar time pressure can apply.
This case study details how a healthtech startup achieved SOC 2 Type II in ninety days by leveraging HIPAA control overlap, selecting a speed-optimized platform and auditor, and making deliberate scope trade-offs. Applicable to healthtech companies facing enterprise procurement deadlines.
Company Profile
Starting Position
| Attribute | Details |
|---|
| Company type | Healthtech SaaS platform (clinical workflow automation) |
| Company stage | Series A; 35 employees |
| Infrastructure | AWS-based; single-region deployment |
| Existing compliance | HIPAA compliance program in place (BAA-ready; risk assessment completed; policies documented) |
| Security baseline | Encryption at rest and in transit; MFA enforced; access controls in place; security awareness training active |
| Trigger for SOC 2 | Enterprise hospital system required SOC 2 Type II report as part of vendor evaluation; procurement deadline in four months |
| Timeline target | SOC 2 Type II report delivered within ninety days of project kickoff |
| Team | One compliance lead (part-time; also handled HIPAA); one engineer (part-time for technical controls) |
Why Ninety Days Was Achievable
| Factor | How It Helped |
|---|
| Existing HIPAA program | Fifty to sixty percent of SOC 2 controls already satisfied by HIPAA compliance |
| Small team size | Fewer employees means smaller sample sizes for access reviews, training, and personnel testing |
| Simple infrastructure | Single cloud provider (AWS); standard architecture; manageable scope |
| Strong security baseline | Encryption, MFA, and access controls already in place from HIPAA requirements |
| Focused scope | Security and Availability criteria only (healthcare buyer priority); excluded Privacy and Processing Integrity |
| Management commitment | CEO prioritized SOC 2; allocated budget immediately; removed blockers |
The Ninety-Day Timeline
Week-by-Week Execution
| Week | Activities | Milestones |
|---|
| Week 1 | Platform selection; auditor engagement; scope definition; gap analysis | Platform connected; auditor contracted; initial gap report generated |
| Week 2 | Gap remediation begins; policies adapted from HIPAA; employee onboarding to platform | Policies uploaded; integrations configured; gap remediation plan established |
| Week 3-4 | Technical gap remediation; configuration changes; evidence collection begins; observation period starts | Major gaps closed; controls operational; observation period officially begins |
| Week 5-8 | Observation period running; continuous evidence collection; remaining remediation; employee training completion | Evidence accumulating in platform; all controls operational and monitored |
| Week 9-10 | Pre-fieldwork preparation; evidence review; auditor readiness call | All evidence organized; pre-fieldwork gaps identified and resolved |
| Week 11-12 | Auditor fieldwork; evidence review; auditor testing; report drafting | Fieldwork completed; no exceptions; draft report reviewed |
| Week 13 | Report finalization and delivery | SOC 2 Type II report issued |
Critical Path Items
| Critical Item | Deadline | Risk if Delayed |
|---|
| Platform connected with all integrations | End of week 1 | Delays evidence collection start; shortens observation period |
| Auditor engagement letter signed | End of week 1 | Cannot start observation period without auditor alignment; fieldwork scheduling delayed |
| All HIPAA policies adapted for SOC 2 | End of week 2 | Policy gaps during observation period; potential audit finding |
| All technical gaps remediated | End of week 4 | Controls not operational for full observation period; insufficient evidence |
| Employee training completed | End of week 6 | Training completion evidence insufficient; potential finding |
| Observation period sufficient | End of week 10 (minimum 8 weeks observed) | Auditor may not accept abbreviated observation period |
HIPAA Control Reuse
Controls That Transferred Directly
| HIPAA Control | SOC 2 Criteria Satisfied | Adaptation Required |
|---|
| Risk assessment (HIPAA Security Rule 164.308(a)(1)) | CC3.1, CC3.2 -- Risk assessment | Minimal -- expand scope beyond PHI to all system data |
| Access controls (164.312(a)(1)) | CC6.1 -- Logical and physical access controls | Minimal -- HIPAA access controls already covered SOC 2 requirements |
| Encryption at rest (164.312(a)(2)(iv)) | CC6.7 -- Encryption at rest | None -- HIPAA encryption satisfied SOC 2 |
| Encryption in transit (164.312(e)(1)) | CC6.7 -- Encryption in transit | None -- TLS already configured for HIPAA |
| Audit controls (164.312(b)) | CC7.1, CC7.2 -- System monitoring and detection | Minimal -- extend monitoring beyond PHI access to all system access |
| Security awareness training (164.308(a)(5)) | CC1.4 -- Security awareness | Minimal -- add SOC 2-specific topics if not already covered |
| Incident response procedures (164.308(a)(6)) | CC7.3, CC7.4, CC7.5 -- Incident management | Minimal -- HIPAA incident response plan covered SOC 2 requirements |
| Workforce security (164.308(a)(3)) | CC1.4, CC6.2 -- Personnel security | Minimal -- background checks and termination procedures already in place |
| Contingency planning (164.308(a)(7)) | A1.1, A1.2, A1.3 -- Availability | Moderate -- HIPAA contingency plan needed expansion for specific RTO/RPO documentation |
Controls That Required New Implementation
| SOC 2 Requirement | Gap from HIPAA | Implementation Effort |
|---|
| Change management (CC8.1) | HIPAA does not specifically require formal change management | Moderate -- configured branch protection in GitHub; documented change management policy; established PR approval requirements |
| Vendor management (CC9.2) | HIPAA requires BAAs but not comprehensive vendor risk assessment | Low-Moderate -- documented vendor inventory; implemented vendor risk assessment questionnaire |
| System description | SOC 2 requires a formal system description; HIPAA does not | Low -- drafted system description with auditor guidance |
| Logical access monitoring (detailed) | HIPAA requires audit controls but SOC 2 expects more detailed monitoring evidence | Low -- configured CloudTrail and centralized logging; set up alerts |
| Board and management oversight documentation (CC1.2) | HIPAA does not specifically require governance documentation | Low -- documented security governance structure; board reporting |
HIPAA-to-SOC 2 Overlap Percentage
| SOC 2 Control Area | Overlap with Existing HIPAA Controls | New Work Required |
|---|
| Access controls (CC6) | 75-85% | 15-25% -- expand beyond PHI; enhance monitoring |
| Risk management (CC3) | 70-80% | 20-30% -- broaden risk scope |
| Monitoring and detection (CC7) | 65-75% | 25-35% -- enhance logging detail; broader scope |
| Incident response (CC7.3-CC7.5) | 80-90% | 10-20% -- minimal adaptation |
| Encryption (CC6.7) | 90-95% | 5-10% -- verify non-PHI data is also encrypted |
| Personnel security (CC1.4) | 75-85% | 15-25% -- SOC 2 policy training; acknowledgments |
| Change management (CC8.1) | 10-20% | 80-90% -- mostly new implementation |
| Vendor management (CC9.2) | 40-50% | 50-60% -- expand from BAAs to risk assessment |
| Availability (A1) | 50-60% | 40-50% -- formalize DR plan; conduct testing |
| Overall | 60-70% | 30-40% |
Platform and Auditor Selection for Speed
Platform Selection Criteria (Speed-Optimized)
| Criteria | Decision | Rationale |
|---|
| Platform selected | Vanta | Largest integration ecosystem; fastest onboarding for AWS-based stacks; strong auditor network |
| Integration priority | AWS, Google Workspace (identity), GitHub, Gusto (HR), Jamf (endpoint) | Core integrations connected in first week; maximum evidence automation |
| Alternative considered | Thoropass (bundled audit) | Ultimately chose Vanta for broader integration depth; separate auditor selection allowed faster scheduling |
| Key speed factor | Pre-built SOC 2 + HIPAA cross-mapping | Vanta identified existing HIPAA controls that satisfied SOC 2; reduced gap analysis time |
Auditor Selection Criteria (Speed-Optimized)
| Criteria | Decision | Rationale |
|---|
| Auditor selected | Boutique firm with startup specialization | Fastest scheduling (fieldwork available within 2 weeks of observation period end) |
| Scheduling availability | Fieldwork scheduled during week 2 of engagement | Eliminated the 4-8 week scheduling gap common with larger firms |
| Vanta familiarity | Auditor was experienced with Vanta evidence format | Reduced fieldwork duration from 2-3 weeks to 1 week |
| Observation period accepted | 8-week observation period (weeks 3-10) | Shorter than typical 12 weeks; accepted by auditor for first Type II given strong control evidence |
| Healthtech experience | Auditor familiar with HIPAA-to-SOC 2 overlap | Understood which HIPAA controls satisfied SOC 2 criteria without extensive re-testing |
Scope Decisions and Trade-Offs
What Was Included
| Scope Element | Decision | Rationale |
|---|
| Trust Service Criteria | Security (CC1-CC9) + Availability (A1) | Hospital buyer specifically evaluated security and availability; met their requirements |
| System boundary | Production application, APIs, and database on AWS | Focused scope on customer-facing systems |
| Observation period | 8 weeks (weeks 3-10) | Shortest period auditor would accept; enabled report delivery within ninety days |
What Was Excluded (Trade-Offs)
| Scope Element | Decision | Trade-Off Accepted |
|---|
| Confidentiality criteria (C1) | Excluded from first engagement | Would add implementation time for data classification; can add in year two |
| Processing Integrity criteria (PI1) | Excluded | Clinical workflow accuracy important but added complexity; plan to include in year two |
| Privacy criteria (P1) | Excluded | HIPAA privacy rule addresses most privacy obligations; P1 adds significant control requirements |
| 12-month observation period | Used 8-week observation instead | Shorter observation means smaller evidence sample; some buyers may question the abbreviated period |
| Formal penetration test | Conducted after report issuance | Used existing vulnerability scan results for CC7.1 evidence; scheduled formal pen test for subsequent quarter |
| Comprehensive vendor risk assessments | Completed for critical vendors only | Remaining vendors assessed in quarter following report |
Trade-Off Risk Assessment
| Trade-Off | Risk Level | Mitigation |
|---|
| 8-week observation period | Moderate -- some enterprise buyers may question the short period | Plan for 12-month observation in year two; communicate with buyer that first Type II used abbreviated period |
| Excluded Confidentiality and Privacy | Low -- hospital buyer focused on Security and Availability | Add criteria in year two before renewal period |
| Pen test after report | Low -- vulnerability scans provided baseline evidence | Schedule pen test in the following quarter; include results in year-two report |
| Abbreviated vendor assessments | Low-Moderate -- auditor may note incomplete vendor coverage | Complete remaining assessments in the following quarter |
Lessons Learned
What Worked Well
| Strategy | Impact | Recommendation |
|---|
| Leveraging HIPAA controls | Reduced new implementation work by 60-70% | Healthtech companies should map HIPAA controls to SOC 2 criteria before starting |
| Engaging auditor in week 1 | Eliminated scheduling delay; fieldwork started immediately after observation period | Engage auditor at project kickoff, not after controls are implemented |
| Using a platform the auditor knew | Reduced fieldwork from 2-3 weeks to 1 week | Select an auditor familiar with your compliance platform |
| CEO sponsorship | Budget approved immediately; blockers removed in real-time | Executive buy-in is essential for accelerated timelines |
| Focused scope (Security + Availability only) | Reduced implementation and documentation effort by 30-40% | Start with criteria that meet buyer requirements; expand in subsequent years |
What Could Be Improved
| Area | Issue | Improvement |
|---|
| Change management readiness | Change management was the largest new implementation; took 2 weeks | Configure branch protection and PR requirements earlier; ideally before SOC 2 project begins |
| Vendor risk assessments | Rushed assessments for critical vendors; remaining vendors deferred | Maintain a rolling vendor assessment program as part of HIPAA compliance |
| Documentation polish | Policies adapted quickly from HIPAA; some lacked SOC 2-specific detail | Invest additional time in policy documentation quality |
| Team capacity | Two part-time people was workable but created stress during weeks 9-12 | Assign at least one person full-time during the final 4 weeks |
Applicability to Other Healthtech Companies
When the Ninety-Day Approach Works
| Factor | Ninety-Day Feasible | Longer Timeline Needed |
|---|
| Existing HIPAA program | Yes -- provides 60-70% control overlap | No HIPAA -- significantly more new implementation required |
| Company size under 50 employees | Yes -- smaller scope, fewer access reviews | Over 100 employees -- larger scope extends implementation |
| Single cloud provider | Yes -- simpler infrastructure scope | Multi-cloud or hybrid -- more complex configuration and evidence |
| Strong existing security posture | Yes -- minimal technical remediation needed | Significant security gaps -- remediation extends timeline |
| Focused TSC scope (Security + Availability) | Yes -- manageable implementation scope | Full five-criteria scope -- substantial additional work |
| Auditor available within 2 weeks | Yes -- no scheduling delay | 8+ week auditor availability -- extends total timeline |
Realistic Timelines by Starting Position
| Starting Position | Realistic Timeline | Key Variable |
|---|
| Healthtech with mature HIPAA program (this case study) | 90 days | Auditor availability and scheduling |
| Healthtech with basic HIPAA compliance | 4-5 months | Gap remediation for incomplete HIPAA controls |
| Healthtech with no existing compliance program | 6-9 months | Full implementation from baseline |
| Non-healthtech startup with no compliance baseline | 5-8 months | No regulatory control overlap to leverage |
Key Takeaways
- We have seen firsthand that a healthtech startup with an existing HIPAA compliance program can achieve SOC 2 Type II in ninety days because HIPAA controls provide sixty to seventy percent overlap with SOC 2 requirements -- access controls, encryption, audit logging, incident response, security training, and risk assessment transfer directly with minimal adaptation, leaving change management, vendor risk assessment, and system description as the primary new implementations
- In our experience, the ninety-day timeline requires three critical speed decisions: engage the auditor in week one (not after implementation), select a compliance platform the auditor is familiar with (reduces fieldwork by fifty percent), and focus the scope on the criteria the enterprise buyer requires (Security and Availability) rather than attempting all five Trust Service Criteria in the first engagement
- Trade-offs are inherent in an accelerated timeline: an eight-week observation period instead of twelve months, deferred penetration testing, abbreviated vendor risk assessments, and excluded criteria (Confidentiality, Privacy, Processing Integrity) are acceptable trade-offs when the alternative is losing an enterprise deal -- we advise clients to plan scope expansion and extend the observation period in year two
- Change management (CC8.1) is consistently the largest new implementation area we see for healthtech companies with existing HIPAA programs -- HIPAA does not require formal change management processes, so configuring branch protection, pull request approval requirements, and deployment controls represents the most significant new work
- The approach scales to healthtech companies under fifty employees with a single cloud provider and existing HIPAA compliance -- companies over one hundred employees, with multi-cloud environments, or without existing HIPAA programs should plan for four to nine months rather than ninety days
- At Agency, we help healthtech companies map their existing HIPAA controls to SOC 2 requirements, identify the fastest path to compliance, and select the platform and auditor combination that minimizes time to report -- particularly valuable when enterprise procurement deadlines create urgency
Frequently Asked Questions
Will enterprise hospital systems accept an eight-week observation period?
In our experience, most hospital procurement teams accept the SOC 2 report based on the auditor's opinion (unqualified or qualified) rather than scrutinizing the observation period length. We have seen that an eight-week observation period with an unqualified opinion satisfies the vast majority of enterprise healthcare procurement requirements. However, some particularly rigorous buyers may prefer a twelve-month observation period. What we advise clients to do is communicate with the buyer's security team during the evaluation to confirm their requirements. Plan to extend to a twelve-month observation for the year-two report regardless.
Can we count HIPAA evidence as SOC 2 evidence?
Yes -- and this is one of the first things we walk healthtech clients through. Where HIPAA controls and SOC 2 criteria overlap, the same evidence satisfies both frameworks. For example, encryption configuration evidence from your HIPAA program demonstrates CC6.7 compliance, access control configurations from HIPAA satisfy CC6.1, and your HIPAA risk assessment supports CC3.1. The compliance platform maps HIPAA controls to SOC 2 criteria, and the auditor evaluates the evidence against SOC 2 requirements regardless of whether it was originally created for HIPAA. We advise clients to ensure the evidence is current (within the observation period) and covers the full SOC 2 scope (not just PHI-related systems).
Should we include the Privacy criteria given that we handle PHI?
What we tell healthtech clients pursuing a ninety-day accelerated timeline is that excluding Privacy (P1) is an acceptable trade-off. HIPAA's privacy rule provides stronger privacy protections for PHI than SOC 2's Privacy criteria, so your existing HIPAA privacy compliance addresses the substance of patient data privacy. Adding P1 to SOC 2 creates additional control requirements (notice, consent, access, disclosure management) that extend implementation time by two to four weeks. We recommend evaluating whether to add Privacy criteria in year two once the baseline SOC 2 program is established and the accelerated timeline pressure has passed.
What if our HIPAA program has known gaps?
This is a conversation we have often, and our advice is straightforward: if your HIPAA program has significant gaps (incomplete risk assessment, missing encryption, inadequate access controls), the ninety-day SOC 2 timeline is not realistic. We recommend addressing HIPAA gaps first -- they represent compliance obligations independent of SOC 2 and create the foundation for SOC 2 control overlap. A healthtech company with basic HIPAA compliance (policies exist but controls are inconsistently implemented) should plan for four to five months rather than ninety days, with the first two months focused on closing HIPAA gaps that simultaneously satisfy SOC 2 requirements.
