The Cybersecurity Information Sharing Act of 2015 created legal protections that allowed organizations to share sensitive cyber threat and incident information with one another and with federal agencies without risking privacy violations or lawsuits. Those protections disappeared when the law expired during the US government shutdown in early October, but Congress later reinstated it on a short-term basis.
Now, with CISA 2015 temporarily reinstated through January 2026, the relief is mixed with unease. The health sector’s window of certainty has been reopened, but only briefly. Internal legal counsel at hospitals and health companies have been re-evaluating which types of threat intelligence they can safely share, how that information must be reviewed, and whether routine exchanges now carry greater legal or regulatory risk.
The short-term extension underscores how fragile the legal foundation for cyber collaboration has become, even as ransomware, AI-driven phishing, and nation-state threats continue to escalate. For the health sector, this moment should serve as a warning. Rather than waiting for policymakers to restore long-term clarity, the sector must fortify the voluntary networks and trusted partnerships that keep intelligence moving regardless of Washington’s pace.
Uncertainty still undermines collaboration
The short-term extension gives the health sector some breathing room, but it hasn’t restored confidence. Even that brief lapse showed how quickly routine sharing can come into question when the legal footing shifts. While information sharing in the health sector has never been better, since October, some firms have added extra layers of legal and privacy review, limiting what they provide to Information Sharing and Analysis Centers (ISACs), and asked whether long-standing agreements with federal partners still offer enough protection.
The questions aren’t academic. Without clear statutory cover, any shared threat intelligence– while exchanged in good faith – could resurface in litigation or be swept into disclosure requests. In a sector built around privacy obligations, that possibility forces teams to think carefully before releasing information they once shared automatically.
Those hesitations create genuine operational drag. A ransomware indicator that once reached thousands of peers within minutes may now sit indefinitely in an internal queue waiting for sign-off. A pattern of suspicious activity that might have prompted a coordinated response instead circulates within a single organization. Each delay narrows collective visibility, giving attackers more room to move and reducing the value of the voluntary networks the sector depends on.
Strengthening sector-led collaboration
The inconsistent federal support and coordination only reinforces how essential voluntary private sector-driven cooperation has become. Across the health sector, Health-ISAC remains as the core channel for trusted exchange, giving organizations a structured way to quickly learn about indicators of compromise, flag active campaigns, and coordinate responses in near real time. Alongside them, other peer-to-peer exchanges fill a similar role for organizations that participate outside the formal ISAC structure.
These systems work because they balance structure with trust. Anonymized data feeds, member-only portals, and carefully managed non-disclosure agreements allow participants to share threat intelligence and cyber incident details without exposing sensitive details or breaching patient privacy. Even without explicit statutory protection, they offer a practical model for responsible collaboration.
Beyond these information-sharing networks, health sector organizations rely on workshops and simulation exercises to strengthen joint response and cross-sector awareness. These activities don’t replace federal guidance, but they form a parallel layer of preparedness that keeps information moving when policy support wavers. The more the sector invests in these voluntary mechanisms, the stronger its collective effectiveness becomes.
Public-private frameworks and data trusts
With policy still unsettled, the health sector has an opportunity to shape the next generation of trusted exchange models. One promising path lies in codifying shared governance frameworks: standardized agreements between hospitals, vendors, and agencies that define how data is exchanged, protected, and audited. These frameworks can be supported by technology rather than statute, using smart contracts, encryption standards, and automated compliance logs to embed accountability into the exchange process itself.
Emerging “data trust” models take this a step further. These are structured digital environments, often powered by AI, that allow organizations to share indicators of compromise or vulnerability data through privacy-preserving protocols. Instead of relying on manual vetting, machine learning algorithms can automatically classify, anonymize, and route sensitive threat intelligence according to predefined rules of engagement.
Still, technology alone cannot solve the trust deficit. To make these systems viable, the health sector needs a consistent language for describing threats, reliable AI oversight mechanisms, and agreed standards for data provenance. Rebuilding confidence will require both policy clarity and technical innovation, with each reinforcing the other.
The next phase of health sector cybersecurity will depend on these hybrid models: part regulatory alignment, part AI-driven data stewardship, and part voluntary sector leadership. The faster these models mature, the less vulnerable the sector will be to the next policy lapse or the next attack.
From uncertainty to resilience
The global health system faces a convergence of cyber risks: AI-driven intrusions, aging infrastructure, and the spillover of geopolitical tensions. These threats are advancing faster than policy can adapt. While lawmakers debate the future of CISA 2015, the sector can’t afford to wait. Real progress will come from strengthening what already works: collaboration built on trust, shared standards, and operational readiness.
Resilience isn’t a solo act; it’s a shared responsibility across the health sector ecosystem. It’s built every time hospitals, vendors, and partners share intelligence, reinforce defenses, and support one another through uncertainty. True security comes from that collective vigilance, from a community moving forward together to protect patients and the systems that sustain their care.
