EHR Downtime Plan for a Small Therapy Practice

Quick answer: A useful EHR downtime plan is a one-page routine for the first hour, the rest of the day, and recovery. It names who activates the plan, approved communication routes, the temporary-note process, and who reconciles those notes. The goal is to keep essential workflows moving without making up new ones under pressure.

Build the card around the work that truly cannot wait:

• Knowing who is expected
• Contacting clients through a channel the practice has already approved
• Following existing procedures for urgent clinical escalation
• Capturing only the necessary temporary information
• Reconciling that information into the official record after restoration

Your process will depend on your practice, vendors, risks, and applicable requirements. This framework is a starting point, not a compliance shortcut.

Before an outage: build the card

Start with roles. In a solo practice, your name may appear several times. In a group, name a primary person and backup for activating the plan, checking vendor updates, handling approved client contact, securing temporary information, and declaring the return to normal.

Add the vendor status page, support route, approved technology contacts, and the exact location of the card and downtime materials.

If limited information will be available offline, define the minimum needed, who may see it, how it is protected, when it expires, and how it is refreshed or destroyed. Do not default to personal email, a personal notes app, consumer messaging, an unsecured spreadsheet, or a printout of the full client list.

First hour: confirm and take control

First, determine what is unavailable. Is the problem limited to one device, one user, part of the EHR, or the whole service? Check the approved support route and status page, then record when you noticed the problem and what you observed.

Next, the person named on the card activates the downtime routine. Writing down that decision point removes uncertainty.

Use only approved information to identify who is expected soon. Decide whether each appointment can proceed within your established policies. If a client needs instructions, use a contact route already named on the card.

For urgent clinical concerns, follow the practice’s existing escalation and emergency procedures. An outage is not the moment to invent a new clinical protocol.

Finally, begin the approved temporary-note process. Label each item clearly as downtime documentation and capture only what is necessary for continued work and later reconciliation.

Same day: keep temporary work controlled

If the outage continues, consistency matters more than clever workarounds.

Use an identifier allowed by practice policy so each temporary item can later be matched to the correct record. Capture the service date, relevant time, author, necessary content, and required follow-up.

Keep an incident log separate from clinical documentation. Record timing, unavailable functions, vendor updates, operational decisions, problems, and unreconciled work.

Limit access by role, follow the approved process for protecting temporary materials, and avoid unnecessary copies. If work cannot continue safely, use the practice’s established decision process and seek qualified guidance where needed.

Recovery: reconcile before moving on

The login screen returning does not mean recovery is complete.

The person named on the card should confirm that the functions and records the practice needs are actually available, then declare the return to normal operations.

Reconcile every temporary note into the correct official record under practice policy. Preserve necessary authorship, timing, and downtime context. Account for each item and its follow-up tasks.

After reconciliation, follow the approved process for retaining or securely destroying temporary materials. Review the incident log, record what failed, and assign each update.

HHS guidance emphasizes backup and recovery preparation, restoration testing, incident documentation, and review. Its audit protocol also considers periodic testing and revision. NIST offers a broader planning model. These sources can inform your process, but they are not a universal certification checklist or a binding therapy-practice rule.

One-page EHR downtime checklist

People and authority

• Person who activates downtime:
• Backup person:
• Person who declares return to normal:

First hour

• Record when the outage was discovered
• Confirm which systems or functions are unavailable
• Check approved vendor status and support routes
• Identify expected clients through the approved process
• Use only approved client-contact channels
• Follow existing urgent-escalation procedures
• Begin the approved temporary-note process

Same day

• Protect temporary information and limit access by role
• Maintain a separate incident and decision log
• Track every item requiring reconciliation or follow-up

Recovery

• Confirm required functions and records are available
• Reconcile every temporary item into the official record
• Complete outstanding follow-up tasks
• Retain or destroy temporary materials under practice policy
• Assign and test plan improvements

Downtime kit

• Current one-page card
• Vendor status page and support details
• Approved communication instructions
• Temporary-note instructions and materials
• Location of existing escalation procedures
• Date and result of last test

Test it this week

Set aside 20 minutes and pretend the EHR is unavailable. Can you find the card? Can you identify an expected appointment through the approved process, use an approved contact route, create a labeled temporary item, and explain how it returns to the official record?

Run a small reconciliation drill using information your practice is allowed to use. Record the result, revise the card, and assign unfinished work. The exercise only needs to reveal missing information before a real outage does.

FAQ

Does my EHR vendor’s backup count as the whole downtime plan?

No. They are important inputs, but the practice still needs a routine for essential work, temporary information, and reconciliation.

Should I print my full client list for emergencies?

Not as a default. Decide what minimum offline information is necessary, who may access it, how it is protected, when it expires, and how it is refreshed or destroyed.

Can I use my personal email or notes app for temporary documentation?

Do not use personal email, personal notes apps, consumer messaging, personal cloud storage, or unapproved spreadsheets for protected practice information. Use only the temporary process approved for your practice.

How often should I test the plan?

The sources support periodic testing and revision but do not set one schedule for every practice. Choose a cadence based on your risks and test after meaningful changes.

Does this checklist establish HIPAA compliance?

No. HIPAA does not automatically apply to every therapist or practice, and a generic checklist cannot establish compliance. Covered entities and business associates within the HIPAA Security Rule’s scope have contingency-planning obligations. Confirm the requirements that apply to your practice with qualified professionals.

Sources

• HHS, Summary of the HIPAA Security Rule
• HHS, Audit Protocol
• HHS OCR, October 2022 Cybersecurity Newsletter
• ASTP/ONC, SAFER Guides
• NIST SP 800-34 Rev. 1, Contingency Planning Guide for Federal Information Systems

Disclaimer

This article provides general business and workflow education. It is not legal, compliance, cybersecurity, or clinical advice, and it does not promise compliance, security, or uninterrupted operations. Confirm applicable requirements and procedures with qualified professionals and your practice’s vendors.