By Sean Dowling, VP & Head of HITRUST, vCISO and Federal Services at Accorian

For organizations pursuing HITRUST certification, the journey promises a structured path to compliance, risk reduction, and market credibility. Yet many underestimate what’s required to get there, and what it costs to do it wrong.

Poor planning in HITRUST adoption leads to ballooning timelines, budget overruns, and staff fatigue. But, when done strategically, the returns can be exceptional: according to Enterprise Strategy Group (ESG), organizations that properly implement HITRUST experience 464% ROI, with 63% increased operational efficiency and significantly reduced breach and compliance costs.

This article explores the hidden costs of poor HITRUST planning and how to avoid them through proper scope management, resourcing, and execution.

Where HITRUST projects go off track

Organizations often stumble into the same traps early in the HITRUST journey. The most common causes of budget and timeline overruns include the following.

Scope creep

When organizations fail to define clear technical and business boundaries, they include too many systems, processes, or geographies, leading to unnecessary complexity.

• Hidden costs: Increased number of controls, inflated assessment scope, and excessive evidence requirements.
• Pro tip: Start with a clearly defined scoping questionnaire and limit scope to the most critical systems (especially in first-time certifications).

Unrealistic timelines

Many teams underestimate the time needed for remediation, policy development, and evidence collection, especially across five HITRUST maturity levels (Policy, Process, Implemented, Measured, Managed).

• Hidden costs: Missed deadlines, overtime expenses, and failed validations requiring retesting.
• Pro tip: Include buffer time for control testing, policy revisions, and sample evidence validation. ESG reports show that HITRUST preparation can drop from 90 to 60 days with good planning.

Underestimating internal resource requirements

Without clear internal ownership, HITRUST projects may drain unallocated IT and compliance resources.

• Hidden costs: Productivity loss, staff burnout, and reduced engagement in both security and business operations.
• Pro tip: Assign a dedicated HITRUST project manager and allocate at least 15% FTE across 4–5 key stakeholders (e.g., IT, HR, Security, Compliance) to maintain momentum.

Cost categories often overlooked in HITRUST planning

What the ESG report reveals about the real economics of HITRUST

Operational efficiency gains

• 30% reduction in audit preparation time
• 63% increase in operational efficiency through reusable documentation and streamlined evidence management
• Eliminated redundant audits as HITRUST certification often replaces client-initiated audits

Risk avoidance

• Up to $9.77M in potential breach-related cost savings (based on Ponemon/IBM data)
• Reduction in cyber insurance premiums by 25% for organizations with HITRUST certifications
• Improved incident response and threat readiness, leading to measurable reductions in unplanned downtime costs — up to $9,000/minute

Revenue enablement

• Clients directly attribute up to 50% of revenue growth to HITRUST certification.
• Customers see accelerated RFP cycles and reduced procurement friction.
• Certification is increasingly required for vendor selection in healthcare and other regulated sectors.

How to build a realistic project plan

Step 1: Conduct an expanded gap assessment

Include control-by-control analysis tied to HITRUST CSF v11.5 (or your applicable version), validate maturity level coverage, and prioritize remediation actions by risk and effort.

Step 2: Define scope with surgical precision

Use HITRUST’s scoping worksheet and threat catalog to define the minimum viable scope — limiting unnecessary business units, cloud assets, or legacy systems.

Step 3: Develop a budget and timeline aligned to remediation reality

Factor in remediation lead time (especially for technical changes like MFA, FIPS encryption, etc.), and allow for 60–90 days of control operation before final assessment fieldwork.

Step 4: Use HITRUST for framework consolidation

ESG’s data reveals that HITRUST customers witness 80% overlap with HIPAA and 60% with PCI and SOC 2 while completing documentation. Take advantage of this to unify evidence collection.

Conclusion: A structured investment beats reactive spending

HITRUST certification, when approached strategically, offers undeniable value, from revenue growth to measurable risk reduction. But organizations must avoid the temptation to “audit their way to compliance.”

The ESG report affirms what experienced assessors already know: success requires structure, stakeholder alignment, and operational readiness. With a potential 464% ROI, HITRUST is not just a cost of doing business — it’s a business accelerator when done right.

HITRUST ROI snapshot

- Tom Kellermann, VP of Cyber Risk, HITRUST

It starts innocently: a pilot that becomes production, a chatbot wired into calendars and CRMs, agents granted access to files and payments. Momentum outruns scrutiny. Teams assure themselves that nothing dangerous could happen to them. Meanwhile, the dark passenger, silent and invisible, settles in next to your AI stack and waits for a turn at the wheel.

Your model doesn’t have to be hacked to become dangerous. It only has to trust the wrong input. A single poisoned record, an indirect instruction, or one over-privileged connector is enough. The question isn’t whether attackers can manipulate AI. It’s whether you’ll notice before the damage is operational, financial, and public.

The problem we created: Connected autonomy, unchecked

The dark passenger is not theoretical. At Black Hat USA in August 2025, three researchers showed how a poisoned calendar invite could hijack a major AI model and flip connected lights, open smart shutters, and even turn on the boiler. Indirect prompt injection can steer an AI system you trust into actions you never intended.

AI systems don’t just answer anymore; they act. What started as a text predictor now reads calendars, invokes plug-ins, touches data lakes, and fires off actions without a person watching. Each new connector, tool, and permission widens the blast radius.

Two shifts amplified this risk.

• Implicit trust: Models and agents routinely treat enterprise sources, SaaS connectors, and user-provided content as safe by default.
• Invisible intermediaries: Helpful layers like SDKs, extensions, and RAG pipelines make it hard to see where an instruction originated or who approved the capability.

That’s the dark passenger’s comfort zone: riding inside “trusted” workflows where guardrails are assumed, not enforced. The danger isn’t abstract; it’s operational.

Significant AI threats and how to address them

Data and model poisoning

Poisoning happens when someone slips harmful information into the data your AI learns from (training) or looks up while answering (like internal knowledge bases). The AI trusts that data, which means it can learn the wrong thing or follow hidden instructions without anyone hacking the system directly. The results range from incorrect decisions to data leaks or backdoor behaviors that only trigger on certain cues.

What to do: Treat data like code: allow-list trusted sources, enforce provenance checks and signed artifacts for datasets/models, and sanitize inputs to strip hidden instructions. Restrict data that RAG can access and monitor for anomalies. If you don’t control the data your AI consumes, you don’t control the AI model’s behavior.

Broken access controls

IBM’s Cost of a Data Breach Report 2025 states that AI adoption is outpacing oversight. The study found that 97% of organizations that suffered an AI-related breach reported they lacked proper AI access controls. Tokens, service accounts, and agent permissions are frequently over-privileged, long-lived, and unbound to accountable humans. That’s how a single connector becomes an attacker’s Swiss Army knife.

What to do: Treat non-human identities like production users. Enforce least-privilege scopes for agents/tools, short-lived tokens, and human accountability for every action an AI can take. This is where incidents may happen. Tighten it first.

Supply chain compromise

Supply chain compromises, including compromised apps, APIs, and plug-ins, were the most common cause of AI security incidents (30%) as per the IBM study. If your agents trust third-party components, your risk surface is as big as the least-secure plug-in in the chain.

What to do: Manage plug-in and API versions. Require digital signatures. Verify dataset provenance. Restrict agent tool scopes and continuously monitor third-party connectors. Small faults in the supply chain can lead to big failures.

Why governance alone is not enough

Governance matters, but governance is not security. Standard frameworks like ISO/IEC 42001 and 23874 provide governance and risk guidance. But they do not address the novel threats inside AI layers. Governance without validated AI security controls leaves organizations exposed. Without enforced, validated controls and robust security measures, governance risks become paperwork while attackers exploit the AI stack.

Why you should care (now)

AI systems drive real operations. But a single poisoned record can trigger wire transfers; a hidden instruction can open a video call; a compromised plug-in can cause data leaks. Boards, customers, regulators, and insurers are no longer impressed by slide decks; they want provable security.

IBM’s numbers show that when AI goes wrong, the bill rises. The global average breach cost landed at $4.44M. If AI agents are making moves in your environment, you need controls that bind them, audit them, and fence what they can touch.

The urgent requirement: AI security and assurance

The real risk is inside the AI layers — the connectors, plug-ins, and permissions that carry novel threats, which no governance program or standard security framework fully covers. This is why AI-specific security and assurance are urgent. Vendors may claim their product “makes you secure,” but history shows that piecemeal solutions fail. What’s needed is holistic security, with validated controls against logical, proven benchmarks.

The dynamic blueprint: HITRUST

This is where HITRUST is relevant. Unlike standards that validate policies, HITRUST validates security. It’s not a new checklist. It’s a validated assurance program that adapts to threat reality and proves controls are operating in practice, not just on paper. HITRUST offers a dynamic security blueprint that strengthens cyber resilience.

HITRUST is cyber threat adaptive. It evolves continuously with intelligence data on attacker tradecraft, ensuring AI controls stay current and keep up with emerging threats. It built the AI Security Certification to secure deployed AI systems. The HITRUST AI Security Certification incorporates up to 44 AI-focused controls that are designed to address the AI attack surface. These controls are independently validated and integrate seamlessly with HITRUST’s proven assurance framework, ensuring that AI systems are not only governed but also secured against real threats.

The AI Security Certification adds to HITRUST’s core security offerings, e1, i1, or r2 for comprehensive resilience and broad cybersecurity coverage. Organizations can establish the baseline and extend it to secure their AI systems and achieve validated AI assurance.

Does HITRUST work?

HITRUST is the only assurance mechanism proven to reduce risk. 99.41% of HITRUST-certified environments were breach-free in 2024, per the Trust Report, evidence that validated, threat-adaptive control sets mitigate real-world risk.

On analyzing traditional breach drivers and AI-specific risks against HITRUST requirements, it’s evident that an e1 + AI Security Certification pairing covers the majority of the IBM breach concepts, such as phishing, compromised credentials, backups, and critically, AI access controls. Stepping up to an i1 + AI Security Certification strengthens coverage for insider threats and recovery plan testing, closing gaps that trip up most programs.

Why trust HITRUST (especially for AI)

HITRUST doesn’t just define controls — it validates they’re operating, harmonizes them across frameworks, and updates them as attacker tradecraft shifts. It scales: start with e1 + AI Security Certification to clamp the biggest risks, uplift to i1 + AI Security Certification for enhanced data protection, and get an r2 + AI Security Certification for the most robust security approach.

Only HITRUST delivers AI assurance grounded in proven methodology, continuous threat adaptation, and independent validation. That’s how you turn AI from a reputational liability into a competitive advantage, backed by evidence.

Conclusion

“The greatest trick the devil ever pulled was convincing the world that he doesn’t exist.” - Charles Baudelaire

Your AI’s dark passenger is very real. Recognize it. Govern it. And most importantly, secure it with proven controls before it takes the wheel.

When evaluating a major investment, one of the first questions leaders ask is: “Is it worth it?”

With security, assurance, and trust initiatives, that question becomes even more pressing. You want to strengthen your organization, but you also need to justify the cost and prove the return on investment.

That’s why we’re excited to introduce the new HITRUST ROI Calculator — a tool designed to give you clear, data-backed insights into the value HITRUST certification can bring to your business.

Why we built it

For years, organizations have shared the business benefits they’ve seen with HITRUST, from faster sales cycles and stronger risk posture to reduced costs and greater efficiency. But until now, there hasn’t been an easy way to estimate those benefits for your specific environment.

The HITRUST ROI Calculator bridges that gap. It helps you

• Quantify the impact HITRUST could have on your revenue, costs, and risk.
• See your potential savings based on real-world data and independent analysis.
• Make informed decisions with confidence, backed by tangible numbers.

How it works

The calculator is simple to use yet powerful in the insights it provides. You enter details about your organization, such as industry, revenue, workforce, and certification goals, and the calculator generates a tailored estimate of your potential ROI.

It measures four key areas of value.

1. Revenue growth: How HITRUST can help accelerate sales cycles, reduce procurement friction, and open doors to new opportunities.
2. Operational efficiency: How much time and effort you can save on certification and audit activities with reusable documentation and streamlined preparation.
3. Cyber insurance savings: How HITRUST can help lower premiums and simplify underwriting by validating your security posture.
4. Risk reduction: How certification strengthens controls, reduces the likelihood of breaches, and improves resilience across your ecosystem.

Your results include an estimated annual benefit, your projected investment, and the overall ROI percentage, all based on assumptions validated by HITRUST customers and market benchmarks.

Why it matters

The ROI Calculator is more than just numbers on a screen — it’s a decision-making tool.

• If you’re considering HITRUST but unsure of the payoff, it provides clarity.
• If you’re building a business case internally, it gives you concrete figures to support your recommendation.
• If you’re comparing investments, it helps you weigh HITRUST against alternatives with measurable data.

HITRUST customers have witnessed a 464% ROI — proof that HITRUST isn’t just about assurance, it’s about meaningful business impact.

Try it today

Decisions about security and trust are too important to leave to guesswork. With the HITRUST ROI Calculator, you can replace uncertainty with clarity and move forward with confidence. Explore it now.