As is the case with SOC2, the "vulnerability scan" requirement here is likely to be meaningless; any automated process that can plausibly be described as instrumental in finding some kind of vulnerability is a "vulnerability scan", so all you have to do is run nmap.
they have comment/request for information sessions for HIPAA rule proposals, which your input would be valued.
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If it is like SOC2 I would expect respected auditors to reject that
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