What is a Unified SOC 2® and HITRUST® Strategy?

Key Takeaways:

• One assessor firm can handle both. A coordinated engagement means evidence is collected once, the 90-day HITRUST fieldwork window aligns with the SOC 2 examination period, and your teams engage with a single assessor team throughout. 
• The overlap is real and substantial. 80% of HITRUST e1 requirements map to one or more SOC 2 Trust Services criteria, and roughly 40–50% of evidence carries over to an e1 assessment. Focused remediation covers the remaining gap. 
• The gaps are targeted and addressable. Controls that rarely appear in SOC 2 reports, including MFA for local privileged access, offline and immutable backups for ransomware resiliency, and email security configurations like SPF/DKIM/DMARC are where most of the remediation work is focused. 
• The e1 is the natural first step. With 43 controls and a focus on essential security hygiene, HITRUST e1 is where 67% of new clients start. It provides immediate market credibility and a clear path to scale toward i1 or r2 as program maturity and market requirements grow.  

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CAN ONE COMPANY HANDLE SOC 2 AND HITRUST?

Yes—and working with a single assessor firm for both is not just possible; it’s the most efficient path forward for healthcare and SaaS organizations. 
 
When a single organization conducts both a SOC 2 examination and a HITRUST assessment within a coordinated engagement, evidence is collected once, audit windows are aligned, and your teams work with one point of contact rather than two separate assessors running parallel processes. That is what a unified SOC 2 and HITRUST compliance strategy looks like in practice. What‘s more, it changes the experience of managing regulatory compliance management considerably. 

WHY ORGANIZATIONS PURSUE BOTH FRAMEWORKS

There is also a meaningful programmatic reason to add HITRUST. SOC 2 examinations are intentionally principle-based: the Trust Services Criteria give organizations flexibility in defining their own controls, which creates room for interpretation on both sides. A recipient of a SOC 2 report may find it difficult to compare controls across vendors or confirm whether a particular threat is addressed. HITRUST addresses that by prescribing specific control requirements mapped to current threat intelligence (including MITRE ATT&CK and is updated continuously. 

The result is a framework oriented around control maturity and operational effectiveness. 

That distinction matters. According to HITRUST’s 2026 Annual Trust Report, 99.62% of HITRUST-certified environments had not reported a breach. A separately published third-party study found that organizations pursuing HITRUST can achieve more than 400% ROI across three areas: business growth, reduced breach risk, and operational efficiency through the reduction of redundant audit activity.  

HOW SOC 2 AND HITRUST COMPLIANCE ALIGN   

Adding HITRUST to an existing SOC 2 program builds directly on what an organization already has.

What overlaps: HITRUST’s own analysis of SOC 2 report data found that 80% of e1 (essential) requirements can map to one or more Trust Services criteria. Organizations moving from SOC 2 to a HITRUST e1 assessment can typically reuse 40–50% of their existing evidence and technical controls. Policies, documentation, and operational testing that already satisfy SOC 2 criteria will often satisfy parallel HITRUST requirement statements as well. 

What the frameworks share at a structural level: Both require documented policies and procedures, access controls, risk assessment processes, and evidence of ongoing operational effectiveness. Organizations that have maintained a disciplined SOC 2 program are working from a solid foundation. 

How evidence timing intersects: HITRUST assessments operate within a defined 90-day fieldwork period, meaning all evidence must be generated and validated within that window. A well-coordinated engagement aligns the SOC 2 examination period with that HITRUST fieldwork window so that testing and evidence collection happen once. This is where an integrated assessment strategy delivers the most tangible time savings. 

There is more detail about this in our recent webinar, now available on demand. 

WHAT HITRUST ADDS BEYOND SOC 2  

The remaining gap, roughly 50% at the e1 level and proportionally larger for i1 and r2, reflects HITRUST’s prescriptive nature. HITRUST prescribes specific requirements at a level of granularity that goes beyond the Trust Services Criteria.

Common gaps identified through HITRUST’s analysis of actual SOC 2 reports include: 

• Multi-factor authentication for local privileged access: While 77% of sampled SOC 2 reports addressed MFA for remote access, only 30% covered MFA for local privileged access, a specific e1 requirement. 

• Phishing prevention controls: Only 11% of sampled SOC 2 reports included both phishing awareness training and email filtering controls. HITRUST requires both. 

• Offline or immutable backups: A specific ransomware resiliency control in the e1 that appeared in none of the sampled SOC 2 reports. 

• Email security standards: SPF records, DKIM, and DMARC configurations, not typically requested as evidence in a SOC 2 examination, are HITRUST e1 requirements. 

Beyond specific control gaps, HITRUST also introduces scope definition differences that organizations need to understand before starting an assessment. SOC 2 scopes to a service offering; HITRUST certifies implemented systems. The boundaries are typically defined by a network boundary or a specific dataset: the systems that store, process, or transmit the protected data in scope. Teams unfamiliar with that distinction often encounter scope issues mid-engagement that slow the certification timeline. 

THE THREE HITRUST ASSESSMENT TYPES 

A unified strategy needs to account for which HITRUST assessment type is appropriate. The three options each serve a different purpose and align differently with a SOC 2 program: 

• e1 (Essential): 43 critical cybersecurity controls addressing essential security hygiene. This is the most common entry point for organizations coming from SOC 2. Sixty-seven percent of new HITRUST clients in the most recent Trust Report chose the e1. It requires only the Implemented maturity level. 

• i1 (Implemented): One hundred and eighty-two controls encompassing the full e1 portfolio plus expanded requirements. Designed to demonstrate leading security practices. Also requires only the Implemented maturity level, with no policy and procedure documentation at that maturity layer. 

• r2 (Risk-Based): The highest level of HITRUST assurance. Control requirements are dynamically scoped to the organization’s specific risk profile, factoring in data volume, data type, regulatory requirements (including HIPAA factors), and other risk inputs. Requires documented policies and procedures across all control domains. This is where organizations with significant PHI or large relying-party ecosystems typically land. 

For organizations already holding a SOC 2 report, the e1 is often the right starting point, providing immediate market credibility and a foundation to scale toward i1 or r2 as the program matures. 

WHAT AN INTEGRATED ENGAGEMENT ACTUALLY LOOKS LIKE  

A unified SOC 2 and HITRUST compliance strategy works because both frameworks share a significant portion of their control universe. The efficiencies are real, and they materialize when the engagement is structured to capture them.

When 360 Advanced conducts both a SOC 2 examination and a HITRUST assessment for the same organization, the work is integrated by design. Client teams work with one assessor team across both frameworks; evidence is collected within a single engagement window, and the fieldwork is coordinated so that SOC 2 testing periods align with HITRUST’s 90-day fieldwork requirement. The result is a single, coordinated engagement: one assessor team, one evidence collection cycle, and fieldwork windows that align across both frameworks. 

This approach also addresses one of the more consequential decisions an organization makes during a HITRUST engagement: how to handle control inheritance from cloud service providers and third-party subprocessors. Third-party eligibility for native inheritance varies, which means scope and responsibility need to be clearly mapped before fieldwork begins, as part of the planning process. 

For organizations managing HIPAA obligations alongside SOC 2 and HITRUST, the integrated approach provides additional leverage. HITRUST originated in part as an operational framework for demonstrating HIPAA compliance, and HIPAA compliance factors can be added directly to any HITRUST assessment type. Organizations that have historically managed HIPAA separately can consolidate that compliance work into a single, certifiable assessment.  

THE CASE FOR A SINGLE COMPLIANCE ASSESSOR

The question “Can one company handle SOC 2 and HITRUST?” comes down to whether the assessor firm holds appropriate accreditations and has structured its engagements to capture efficiencies across both frameworks. 

360 Advanced is a licensed CPA firm authorized to perform SOC examinations in accordance with AICPA standards and is a HITRUST CSF Assessor. Both assessment types are conducted by the same team under an integrated methodology, with coordination built into the engagement structure from the start. 

For compliance leaders navigating SOC 2 and HITRUST at the same time, the value is straightforward: less audit fatigue, better alignment between evidence and requirements, and a clear path from e1 certification toward the higher assurance levels your market may require.  

GETTING STARTED

Whether your organization is pursuing HITRUST for the first time or expanding an existing SOC 2 program, the starting point is understanding your current baseline. A gap assessment against the relevant HITRUST assessment type (e1, i1, or r2) provides that picture and identifies what needs to be in place before the validated assessment begins. 

360 Advanced works with healthcare and SaaS organizations to assess that readiness, coordinate evidence collection across frameworks, and guide teams through the full HITRUST certification process.