The TPRM Top 10 - Hidden Vendor Risks

Vague scopes, inconsistent assurance methods, and limited exception reporting can obscure material control gaps until a vendor has already been approved.

Why it Matters

Vendor due diligence is intended to identify material weaknesses before the organization commits to the relationship. In practice, TPRM teams often receive evidence that is difficult to interpret or incomplete for the product or service being provided. Reports may be unclear about what was tested, which systems were included, or how deeply controls were evaluated.

“You don’t understand fully what they actually tested versus what they didn’t." --TPRM Leader commenting on their assurance review process

HITRUST conversations with TPRM leaders identified that material risks can remain obscured even when documentation is available. TPRM leaders reported receiving assurance reports that were vague about scope, exceptions, and shared responsibilities. This forces TPRM analysts to interpret inconsistent evidence and request supplementary information before they can determine whether an identified weakness is relevant to the systems or services on which the organization depends.

This creates a dangerous form of uncertainty. Documentation may be available, but the team still cannot determine whether the evidence covers the product or services on which the organization will rely. Additional follow-up requests may close some gaps, but they also increase review time and vendor friction.

What the Evidence Shows

New 3^rd party research coming soon from HITRUST and CHIME* surveyed over 100 qualified TPRM leaders and found that:

• 100% of organizations reported that their TPRM team discovered at least one gap or vulnerability in a vendor after approval, with 18.6% of the programs frequently identifying gaps or vulnerabilities.
• 16.7% of respondents reported that they frequently discovered vendor gaps after approval when only using security questionnaires.
• However, when organizations evaluated vendors using a third-party verified assurance mechanism (i.e. HITRUST, SOC 2, or ISO 27001) only 2.9% of programs frequently had a vendor gap or vulnerability after approval (and none were frequent when using HITRUST)

         

 Additionally, the 2026 Panorays CISO Survey for Third-Party Cyber Risk Management found that “while 60% of CISOs report an increase in third-party security incidents, only 15% say they have full visibility into those risks.”

What TPRM Leaders Can Do

• Require evidence that clearly identifies scope, control coverage, exceptions, and shared responsibilities.
• Evaluate whether the assurance applies to the specific service, data, and operational dependency under review.
• Use independently validated assurance for higher-risk vendors and define when supplemental evidence is still required.
• Connect identified gaps to remediation, mitigating controls, contractual protection, or explicit risk acceptance before approval.

Coming Up in the Next Blog in the Series

*CHIME Digital Health Analytics. Third-Party Risk Management Assurance: Strategic Market Validation Survey. Commissioned by HITRUST. Ann Arbor, MI: College of Healthcare Information Management Executives, Digital Health Analytics 2026. In July 2026, HITRUST commissioned CHIME Digital Health Analytics to conduct a blinded market-validation survey of 102 qualified respondents from separate healthcare provider organizations with more than $1 billion in annual revenue. Respondents represented security and GRC leadership, TPRM ownership, procurement and vendor management, legal and contracting, and executive leadership. Every participating organization actively managed at least 200 third-party vendors, and 87% managed more than 500.