Cybersecurity Information Sharing Act of 2015 (CISA)

The Cybersecurity Information Sharing Act of 2015 (CISA) was enacted to provide a formal framework for voluntary information sharing of cyber-threat indicators and defensive measures between private entities and the federal government. Created in response to escalating threats to critical infrastructure, including healthcare systems, the law drew on the fact that private-sector organizations hold vital intelligence about adversaries that, if shared, can strengthen collective resilience.

The law encouraged entities (including those subject to HIPAA cybersecurity obligations) to collaborate by offering legal protections. Specifically, sharing threat indicators was authorized under certain conditions, so that disclosing them would not, by itself, trigger liability or waive legal privilege. For healthcare organizations already charged with protecting patients’ digital footprints while managing complex credential management across clinical workflows, the ability to monitor systems and share threat-relevant data under CISA provided useful assurance for their cybersecurity strategies.

Within the healthcare context, CISA enabled greater alignment with frameworks such as the Health Sector Coordinating Council (HSCC) and its recent Sector Mapping and Risk Toolkit (SMART) initiative, which supports mapping third-party and vendor risk across clinical and administrative workflows. Because healthcare organizations deal with large vendor ecosystems, device inventories, third-party data processors, and service contractors, this toolset complements the information-sharing ethos of CISA by helping visualize systemic dependencies and risk. In practice, legal protections under CISA, such as antitrust safe harbor and Freedom of Information Act exclusion for certain shared indicators, reduced organizational hesitation around sharing threat intelligence with the federal government. Through these mechanisms, healthcare cybersecurity companies, credential-management systems, and other cybersecurity solutions for healthcare organizations could participate more confidently in threat-sharing networks, improving detection and response.

However, key provisions of CISA 2015 included a sunset clause set to expire on September 30, 2025. Because Congress did not finalize a long-term re-authorization before that date, the law lapsed, creating a legal and operational gap for entities that had relied on its statutory protections. This expiration means the specific protections that enabled sharing under the law (including immunity protections and safe harbors) are no longer guaranteed. The risk exposure for healthcare organizations rises: reluctance to share threat indicators with peers or government entities may increase, and malicious actors may exploit the reduced coordination. Given the healthcare sector’s complexity and reliance on interconnected systems — clinical, administrative, billing, supply chain — the absence of that statutory sharing framework could slow down proactive defense efforts and increase liability risk in the event of a breach or system disruption.

Healthcare cybersecurity companies are entities posed to help make a material difference in evolving regulatory and threat landscapes. Imprivata offers proven concepts in credential management, role-based access control, session monitoring, and vendor oversight — all key to reducing attack surface and strengthening an organization’s cybersecurity posture. By implementing Imprivata cybersecurity solutions for healthcare, organizations gain better visibility, control, and resilience. Imprivata helps healthcare organizations maintain robust cybersecurity despite the uncertainty around information-sharing legislation, making the threat landscape less daunting and ensuring mission-critical functions continue uninterrupted.