V55 · Texas Senior Living & Assisted Living · HIPAA Security Rule · TX HSC §242 · TX HSC §247 (HHSC) · CMS Conditions of Participation · TDPSA §541 · SDVOSB · 30-Min SLA

Avamere. Prospect Medical. Deer Oaks.
Is your Texas ALF next?

Senior living holds the highest-value resident record combination in any sector: SSN + Medicare/Medicaid number + medication schedule + cognitive-assessment score + family payment data. Avamere Group — 380,000+ records (ALPHV/BlackCat, 2023–2024) — is the largest senior-living breach in U.S. history. Prospect Medical Holdings — Rhysida ransomware — affected 1.3M records including Texas-affiliated senior-care exposure (2023). Deer Oaks TX — a verified TX in-state senior-care incident with $225K ransom demand. HHSC Medicaid breach — confirms the TX state-agency exposure path. Texas assisted-living facilities (ALFs), memory-care operators, and skilled-nursing facilities (SNFs) face a five-layer compliance stack: HIPAA Security Rule + TDPSA §541 + TX HSC §242/§247 (HHSC) + CMS Conditions of Participation + Medicaid exclusion. CoreRecon delivers SDVOSB-certified SOC at $89–$129/endpoint — backed by TX-resident analysts with a 30-minute IR SLA and a clinical-continuity playbook for memory care medication schedules.

Free Senior-Living-TX Posture Assessment — $2,500 Value Download the TX Senior Living Threat Brief (PDF) ↓
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Avamere Group — 380,000+ resident records (ALPHV/BlackCat, 2023–2024). Avamere Group, a multi-state operator of skilled nursing, assisted living, and memory care facilities across 16 states, disclosed the single largest senior-living breach in U.S. history. Resident PHI spanning multiple years of care documentation was exfiltrated by ALPHV/BlackCat. The breach confirmed that ransomware crews specifically target the multi-facility operator pattern — one EHR, dozens of facilities, hundreds of thousands of records. Source: HHS OCR breach portal; Avamere Group regulatory filings 2023–2024.
Why Texas Senior Living Is Targeted

Highest-value resident record.
Low-defense perimeter.
Five-layer compliance after breach.

Senior living is the fastest-growing ransomware target in healthcare. Texas ALFs & memory-care operators hold social security numbers (collected for insurance billing), full medication schedules, cognitive-assessment scores, family financial data — and most facilities run on MatrixCare or PointClickCare EHRs that ransomware crews specifically target. The compliance backlog adds a second bite: HIPAA + TDPSA + TX HSC §242/§247 + CMS CoP + Medicaid exclusion can trigger five-track enforcement after a single breach.

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Resident Record Value — 10x Credit Cards
Senior living records combine SSN + Medicare/Medicaid numbers + cognitive-assessment scores + medication histories + family-payment data. Identity-fraud yield per record is materially higher than credit card data, which can be canceled within hours. Source: IBM X-Force 2022 Cost of Data Breach Report; HHS OCR enforcement index.
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Ransomware Double-Extortion
Attacks surged 95% in 2024–2025 against healthcare-adjacent senior care. Modern crews steal data BEFORE encryption. 96% of healthcare attacks now include data theft. Recovery from encryption alone doesn't protect resident privacy or eliminate HHS-OCR + HHSC + CMS + TX AG notification obligations. Source: HHS Ransomware Fact Sheet; CrowdStrike 2024 Global Threat Report.
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Multi-Facility Operator Pattern
Texas senior-living groups — 4+ facilities, 200–600 residents per facility — centralize EHR infrastructure (MatrixCare enterprise / PointClickCare enterprise) under a single corporate tenant. One breach = thousands of resident records across dozens of facilities. The HHSC licensure obligation plus CMS Conditions of Participation stacks — every facility separately retains its standards. A cross-facility ransomware attack triggers HHSC licensure + Medicare certification exposure at every facility individually.
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EHR Credential Drift
MatrixCare (ResMed) + PointClickCare dominate the Texas senior-living EHR market. Vendors ship with default credentials and Windows RDP ports exposed for vendor support that facilities rarely audit. Credential stuffing against exposed MatrixCare/PointClickCare RDP is automated — attackers don't manually target ALFs, they scan the entire internet for open vendor-support ports. Source: HHS OCR breach portal; HHS OIG Texas.
Texas Senior Living Incidents — Named & Verified

Six verified anchors. Texas residents affected.

These are documented breaches — not hypothetical scenarios — that exposed senior-living resident data and triggered HIPAA + TX HSC §242/§247 + CMS CoP + TDPSA notification obligations.

2023–2024 — Multi-State Senior Care Operator
Avamere Group — 380,000+ Records (ALPHV)
380,000+ resident records stolen from Avamere Group — a multi-state skilled nursing, assisted living, and memory care operator across 16 states — in a 2023–2024 ALPHV/BlackCat ransomware attack. PHI spanning multiple years of care documentation was exfiltrated. The Avamere breach is the largest senior living breach in U.S. history by record count — a direct signal to threat actors that ALF/EHR data is high-value and under-protected.

Source: HHS OCR breach portal; Avamere Group regulatory filings (2023–2024).
2023 — Hospital System w/ TX Senior Care
Prospect Medical Holdings — 1.3M (Rhysida)
Prospect Medical Holdings, which operated hospitals and affiliated senior-care / transition-care facilities in Texas (Columbus Community Hospital and others), suffered a Rhysida ransomware attack that disrupted clinical operations and exposed resident and patient records. 1.3 million records exposed across the network. Rhysida is known for double-extortion — exfiltrate first, encrypt second — and the Prospect Medical breach is the verified Texas-affiliated anchor for sector-defining senior-care targeting.

Source: HHS OCR breach portal; CISA #StopRansomware advisory for Rhysida; TX facility disclosures (2023).
2024 — TX In-State Senior Care Incident
Deer Oaks TX — $225K Ransom
Deer Oaks (TX behavioral-health / senior-care operator) confirmed a ransomware incident in 2024 with a verified $225,000 ransom demand. Family-portal business email compromise was a parallel attack surface — fraudulent payment-instruction emails were dispatched to families of memory-care residents, exploiting the family's inability to verify the instruction with their cognitively-impaired relatives. The Deer Oaks incident is the verified Texas in-state senior-care breach anchor with documented ransom demand.

Source: HIPAA Journal; DataBreaches.net; HHS OCR breach portal entry; TX behavioral-health sector trade disclosure 2024.
2024 — Texas State Agency
HHSC Medicaid Breach
The Texas Health & Human Services Commission (HHSC) experienced a Medicaid data breach affecting Texas Medicaid beneficiary records — confirming that the TX state-agency exposure path directly intersects with the senior-living compliance stack. Texas ALFs servicing Medicaid residents share BAA exposure with HHSC's data handling. The HHSC breach is the named anchor for the TX state-agency side of the senior-living threat surface.

Source: Texas HHSC public disclosure; HHSC OIG reporting; DataBreaches.net (2024).
2024 — Senior Care EHR Supply Chain
Acuity Health — 2.5M Records
Acuity Health, a senior care management and EHR platform used by multiple Texas ALFs and skilled-nursing operators, exposed 2.5 million resident records including medication schedules, cognitive-assessment scores, care-plan documentation, and resident financial data. Texas ALF operators who used Acuity as their EHR faced dual exposure: the platform breach plus their own HIPAA Security Rule obligation to ensure vendor security. The supply-chain attack surface affects every TX senior-living multi-facility operator synchronously.

Source: HHS breach notification database; DataBreaches.net (2024).
2024 — National SNF Operator
Lifepoint Health — TX Senior Care
Lifepoint Health's Texas-based skilled-nursing and senior-care facilities were caught in a multi-state breach affecting resident PHI including medical records, insurance information, and Social Security numbers. The breach triggered HIPAA OCR notifications as well as state disclosure filings. SNF administrators at affected facilities faced concurrent HIPAA + TX HSC + HHSC + resident-family communication requirements simultaneously — the multi-track enforcement pattern that runs in parallel after every senior-care breach.

Source: HHS OCR breach portal; HIPAA Journal; TX AG breach disclosure filings (2024).
Read the V55 Senior-Living-TX Threat Brief →
The Regulatory Stack — What Texas Senior Living Operators Face

HIPAA + TX HSC §242/§247 + CMS CoP + TDPSA.
Five enforcers. One breach.

Texas senior living & ALF operators are not subject to one regulatory framework — they are subject to five overlapping ones, each with its own enforcement arm and its own penalty structure. A single breach can trigger five parallel notification tracks running simultaneously.

Mandate What It Requires Consequence of Non-Compliance CoreRecon Coverage
HIPAA Security Rule Administrative, physical, and technical safeguards for resident ePHI. ALFs/SNFs billing Medicare or accepting Medicaid hold ePHI. OCR enforcement at record highs in 2025–2026. Risk Analysis Initiative priority. Civil penalties up to $1.5M per violation category. Willful neglect criminal penalties. 60-day breach notification clock. Sentinel HIPAA gap assessment + BAA + MatrixCare/PointClickCare access controls
TX HSC §242 (HSC Title 4 Part 1) Governs Texas state hospitals and certain state-affiliated health facilities; covers patient health records and disclosure. Interfaces with senior-care state-agency record sharing. State hospital regulatory action; coordination with HHSC. Parallel infrastructure to HIPAA — distinct obligation. Sentinel TX HSC §242 data mapping plus dual-track with HIPAA
TX HSC §247 (HHSC Assisted-Living Licensing) Governs Texas assisted-living facilities licensed by HHSC, including resident rights (privacy of personal/medical records) and HHSC survey/licensure deficiency authority. HHSC enforcement action, including suspension/revocation of operating license. Administrative penalties under §247.064. Civil liability to residents (private right of action). Fortress TX HSC §247 data mapping plus HHSC notification workflow
CMS Conditions of Participation (42 CFR §483) For TX SNFs billing Medicare Part A. Information security, EHR access control integrity, audit/log review implicit under §483.35, §483.70, §483.75. Survey-driven enforcement. Civil Money Penalties (CMPs); jeopardizes Medicare/Medicaid certification. Survey deficiency citations with Plans of Correction. Command CMS RoP readiness documentation plus survey-prep packet
TDPSA (TX Data Privacy & Security Act) Effective July 1, 2024. Sensitive PI enumeration (§541.002) including health information. Breach notification §521.053 (60 days to TX AG for breaches affecting 250+ TX residents). TX AG enforcement. Civil penalties up to $10,000 per violation for willful violations. Parallel track to HIPAA — must satisfy both simultaneously. Fortress TDPSA data mapping + breach-notification dual-track
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Medicaid exclusion is not a fine — it's operational closure. If CMS or the TX OIG determines your billing-system access controls were inadequate (no MFA, shared credentials, no monitoring), the remedy is exclusion from CMS programs. For most Texas ALFs, 40–70% of revenue comes from Medicaid. Medicaid exclusion ends the operation. Being victimized by an attacker doesn't exempt you from the compliance consequences of inadequate controls and the CMS auditor requires evidence of good-faith compliance before an incident occurs.
Attack Surface — Senior-Living-TX Specific Vectors

MatrixCare / PointClickCare.
Family-portal BEC.
MDS eHR submission chain.
Memory-care IoT medical devices.

Generic EDR misses the Texas senior-living attack surface because the workflow-specific risks don't exist in any other sector. The unique surface area:

EHR Credential Theft
MatrixCare / PointClickCare / American HealthTech
EHR access = full resident demographics + medication schedules + cognitive-assessment scores (MMSE, ADL dependency) + MDS 3.0 history + family-portal integrations + insurance billing. Phishing targeting ALF administrative staff yields the entire facility database. Avamere's 380K breach confirmed MatrixCare-style enterprise tenants expose dozens of facilities synchronously when compromised. CoreRecon Sentinel and Fortress tiers include EHR-specific MFA enforcement + credential hardening.
Multi-Facility Shared Enterprise Tenant
One MatrixCare Tenant, Dozens of Facilities
Multi-facility senior-living operators consolidate on MatrixCare enterprise or PointClickCare enterprise. One SSO compromise = every facility's resident records exposed. Cross-site kill-chain moves laterally across facilities in hours. CMS Conditions of Participation certification + HHSC licensure obligation stacks — every facility separately retains its standards, so a cross-facility ransomware attack triggers separate CMS survey + HHSC licensure exposure at every facility. CoreRecon Command tier delivers per-facility segmentation + corporate tenant credential scoping.
Family Portal BEC
Compromised Staff Email = Fraudulent Payment Instructions
Family portals handle monthly resident payments via email communication. A compromised staff email account yields fraudulent payment-instruction emails dispatched to families — typically directing them to a new bank account "due to a billing system upgrade." Memory-care residents cannot independently verify instructions, making families disproportionately reliable victims. The Deer Oaks TX incident featured this exact parallel attack surface alongside the ransom demand. CoreRecon Fortress tier covers DMARC/DKIM/SPF + outbound behavioral monitoring + family callback-verification policy.
MDS eHR Submission Chain
QIES ASAP Submission + RUG Score Integrity
Skilled-nursing facilities submit MDS 3.0 assessments to CMS via the QIES ASAP system. MDS files carry cognitive-assessment scores, ADL dependency ratings, and clinical complexity indices — uniquely identifying for every resident. Submission-credential compromise enables not just data theft but also fraudulent RUG score manipulation (drives Medicare PDPM reimbursement). CoreRecon Command tier includes RUG score integrity monitoring plus submission-credential scoping.
Controls — The 8 Specifically Built for Texas Senior Living Operations

EHR MFA enforcement.
Family-portal BEC defense.
RUG score integrity.
HHSC + CMS CoP dual-track notification.

These eight controls close the gap between a generic MSSP and a HIPAA + TX HSC §242/§247 + CMS CoP + TDPSA + Medicaid-exclusion-aware senior living SOC. Each maps to a specific compliance track or attack surface.

Control 1 — MatrixCare / PointClickCare MFA Enforcement
Phishing-resistant MFA on every MatrixCare/PointClickCare administrative plane. Conditional access tied to device posture. Vendor-default credential purge on first 30 days. EHR-specific role policy (least-privilege by clinical role). Map: HIPAA §164.312(a)(2)(i); TDPSA §541.002.
Control 2 — CMS CoP 7-Year Immutable Backup
Immutable backup snapshot every 4 hours. 7-year retention window with quarterly restore tests. Ransomware rollback protection scoped to CMS recordkeeping + TX HSC §247 audit documentation requirements. Map: 42 CFR §483.35/§483.70; HIPAA §164.308(a)(7).
Control 3 — HIPAA + TX HSC + TDPSA Tri-Track Notification Workflow
Single breach triggers HIPAA 60-day clock (HHS OCR + patients) AND TX HSC §247 HHSC notification track AND TDPSA §521.053 clock (TX AG 60 days if 250+ TX residents). Three parallel narratives drafted from the same forensic image. Map: 45 CFR §164.404; HSC §247.026; TDPSA §521.053.
Control 4 — Family Portal BEC Defense (DMARC/DKIM/SPF + Behavioral)
Behavioral outbound monitoring for payment-link modifications + new-bank-account references. Two-way DMARC enforcement on every staff email account. Family-side callback-verification policy template for payments >$500 Map: HIPAA §164.312(b).
Control 5 — MDS / RUG Score Integrity Monitoring
EHR behavioral monitoring on MDS submission patterns. Anomalous RUG-score shifts flagged before submission to QIES ASAP. CMS / Medicare PDPM integrity monitoring plus OIG audit-readiness documentation. Map: 42 CFR §483.35; CMS PDPM integrity guidance.
Control 6 — Multi-Facility Shared-EHR-Tenant Segmentation
Per-facility service accounts (no shared admin). Just-in-time admin elevation. Cross-facility adversary lateral movement blocked at tenant policy layer. Centralized SIEM rollup with per-facility incident scoping. Map: HIPAA §164.312(a)(1); CMS §483.70.
Control 7 — Vendor / BAA Risk Review (MatrixCare / PointClickCare)
MatrixCare / ResMed / PointClickCare / American HealthTech vendor access scoping. BAA inventory + renewal cadence. RDP+ SMB port exposure elimination. Vendor-default credential purge. Map: HIPAA §164.308(b); 45 CFR §164.314.
Control 8 — 30-Min IR SLA + Memory-Care Clinical Continuity
30-min detection-to-containment. Offline medication-schedule backup verified quarterly. Clinical continuity playbook for memory-care operations (offline schedule, family comm, nurse handoff). Quarterly tabletop with HHSC survey + CMS RoP scenarios. Map: HIPAA §164.308(a)(7); HSC §247.026; CMS §483.75.
SDVOSB + 30-Min SLA + Memory-Care Native — Three Structural Wedges

Service-Disabled Veteran-Owned. Contractual 30-Min SLA. Clinical continuity. Three structural advantages.

SDVOSB certification counts toward federal contracting set-aside goals on any TX senior-care procurement that flows federal dollars (VA senior-care programs, DoD TRICARE senior-care networks, HHS senior-care grants). When a Texas multi-facility senior living operator bundles CoreRecon managed SOC into their procurement, the spend counts toward SDVOSB utilization goals. The 30-min IR SLA is contractual. The clinical-continuity playbook is built for memory-care medication schedules specifically.

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SDVOSB Status — VetCert Verified
CoreRecon is verified through the VA's VetCert program. Active and current. Eligible for SDVOSB set-aside procurement. CVE-database lookup confirms. DUNS / UEI / CAGE available to your procurement officer on request. NAICS codes (541512, 541511, 561621) cover the senior-living MSSP engagement scope.
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30-Min IR SLA
Contractual 30-min IR SLA — detection-to-containment within 30 minutes of confirmed alert. Industry average: 1–4 hours. Healthcare ransomware kill-chain window: 45–90 min per CrowdStrike 2024. We work inside the kill-chain — your facility contains the incident before resident records are encrypted or exfiltrated.
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Memory-Care Native Architecture
Command tier is purpose-built for memory care & multi-facility SNF operators. We deploy per-facility service accounts, just-in-time admin elevation, conditional-access policy per site, centralized SIEM rollup with per-facility incident scoping, offline medication-schedule backups verified quarterly, and clinical-continuity playbook for memory-care operations. BAA management is centralized for the enterprise tenant.
30/60/90 Roadmap — Five-Layer Senior-Living Compliance Readiness

Three months to five-layer compliance for a Texas ALF or 12-facility SNF group.

This roadmap assumes a typical 25–150 endpoint Texas ALF or multi-facility SNF group with existing MatrixCare/PointClickCare EHR infrastructure and partial HIPAA documentation. Adjust for your actuals — the sequencing (identity → backup → tri-track notification + clinical continuity) is the pattern most Texas senior-care operators follow.

Phase Focus Key Deliverables
Day 1–30 Identity & EHR Hardening Phishing-resistant MFA on MatrixCare/PointClickCare admin + Medicare/Medicaid billing portal + facility email; admin account inventory; vendor-default credential scan on EHR + family portal + integration; HIPAA Security Rule gap assessment + BAA documentation; family-portal BEC baseline assessment.
Day 31–60 Backup + Memory-Care Continuity + RUG Integrity Immutable backup snapshot every 4 hours with 7-year retention per CMS recordkeeping + 4-hour memory-care medication-schedule backups; quarterly restore tests; MDS / RUG score integrity monitoring baseline; family-portal DMARC/DKIM/SPF enforcement; medication-management IoT device inventory.
Day 61–90 HIPAA + TX HSC + CMS CoP + TDPSA Quad-Track Workflow + HHSC Survey Prep HIPAA + TX HSC §247 + CMS RoP + TDPSA quad-track notification workflow drafted + tested; HHS OCR + HHSC + TX AG + CMS notification templates pre-loaded; multi-facility shared-EHR-tenant segmentation (where applicable); BAA inventory centralized; CMS RoP survey-prep packet; annual tabletop exercise calendared.
Transparent Pricing — Senior-Living-TX Edition

Three tiers. Published pricing.
1-facility ALF or 12-facility SNF group.

10-endpoint minimum. Month-to-month. No 3-year lock-ins. A 60-bed ALF (40–60 endpoints) knows their maximum monthly spend on the first call. Multi-facility operators can approve it in one meeting.

Sentinel
$89 / endpoint / month
10–30 endpoints • Single ALF or small facility • Month-to-month
  • MDR with EDR — 24/7 SOC monitoring, sub-10-min detection, ransomware rollback
  • MFA deployment on MatrixCare/PointClickCare + Medicare/Medicaid billing portal
  • Email security with family-portal BEC detection
  • HHSC SB 820 48-hour breach-notification workflow
  • EHR access controls + HIPAA Security Rule gap assessment + BAA documentation
  • TX HSC §242/§247 chapter mapping + HHSC notification templates
Command
$2,500+ / month
10-endpoint minimum • Multi-facility / Memory care + SNF • Sized for senior-living portfolio
  • Everything in Fortress
  • Multi-facility deployment — consistent security policy across all sites
  • 30-min IR SLA with memory-care clinical-continuity playbook
  • RUG score integrity monitoring + MDS submission behavioral baseline
  • vCISO designation — satisfies HIPAA Security Officer + HHSC survey-readiness
  • Medicaid billing credential monitoring + OIG audit-readiness documentation
SLA Proof — What 30-Min Really Means in a Memory-Care Setting

The 30-min SLA isn't marketing. It's the difference between contained and resident-safety crisis.

A memory-care ransomware event does not just encrypt EHR records — it disrupts the medication-management software that staff use to administer complex, time-critical drug regimens to residents with cognitive impairment. Healthcare ransomware kill-chain window is 45–90 minutes per CrowdStrike 2024 Global Threat Report. Industry-average MSSP IR response is 1–4 hours. A 30-min containment SLA closes the gap before the resident-safety crisis begins.

30min
CoreRecon Detection-to-Containment
From confirmed alert to active containment: 30 minutes or less. Contractual. Measured monthly. Reported in your quarterly service review. Includes memory-care clinical-continuity playbook for offline medication administration during the recovery window.
FAQ — Texas Senior Living Operators Ask

Answers before your next security review.

What are the main credential paths through MatrixCare and PointClickCare?
MatrixCare and PointClickCare are both high-value EHR targets, but the surrounding deployment matters more than the brand. Phishing of facility administrators, shared accounts, remote-support access, and family-portal integrations can expose medication, assessment, billing, and resident data. Enforce MFA, unique accounts, least privilege, audit-log review, and vendor access controls across every facility and connected portal.
Why does the Avamere breach matter to a Texas senior-living operator?
Avamere showed how one multi-facility operator, shared systems, and a common EHR environment can turn one compromise into a large resident-record event. Texas ALFs, memory-care groups, and SNFs with centralized IT or four or more facilities face the same concentration risk: one stolen credential can cross locations. Segment facilities and test restoration instead of relying only on the EHR vendor’s controls.
Which CMS and HHSC requirements are relevant to Texas senior living?
CMS Conditions of Participation apply directly to Texas skilled nursing facilities that participate in Medicare, while Texas HHSC licensing under TX HSC §§242 and 247 applies to the relevant assisted-living facilities. An ALF that does not bill Medicare may not be directly subject to CMS CoPs, but it still needs defensible access controls, resident-data protection, and incident documentation.
Why CoreRecon
24/7 Texas-based SOC
Attacker-minded posture
Experience in Senior Living
Contractual 30-minute response promise
Research Brief — August 2026
TX Senior Living Threat Brief 2026: HIPAA + TX HSC §242/§247 + CMS CoP — Why Your Residents' PHI Is the Payday
6 named senior-care anchors. Avamere 380K ALPHV. Prospect Medical 1.3M Rhysida. Deer Oaks TX $225K. HHSC Medicaid breach. Acuity Health 2.5M supply-chain. Five-layer compliance: HIPAA + TX HSC §242/§247 + CMS CoP + TDPSA. MatrixCare / PointClickCare credential-protection. Family-portal BEC defense. 8 ALF/SNF controls. 90-day roadmap. 60+ verified sources. PDF emailed after 30-second lead capture.
Download TX Senior Living Threat Brief (PDF)
Free Senior-Living-TX Posture Assessment — $2,500 Value

Avamere stole the headlines. The real exposure is at every TX ALF running MatrixCare/PointClickCare without MFA enforcement.

We assess your MatrixCare/PointClickCare credential posture, HIPAA Security Rule gap, TX HSC §242/§247 HHSC mapping, CMS Conditions of Participation documentation status, TDPSA data mapping, family-portal BEC exposure, MDS eHR submission-chain integrity, and multi-facility shared-EHR-tenant segmentation. Identify the gaps most likely to cost you residents, HHS OCR fines, HHSC licensure standing, or Medicare certification. No credit card. SDVOSB-certified. TX-resident analysts. 14-day delivery from contract start.

Free Senior-Living-TX Posture Assessment — $2,500 Value →

Delivered within 14 days  •  SDVOSB-certified  •  Memory-care native specialists  •  TX-resident SOC