HIPPA and X-Rays

Answer: HIPAA does not make any specific requirements for X-rays. As with all medical materials, you need to provide reasonable safeguards to protect them.

You should have written guidelines stating who can access them and some protection in place to keep just anyone from looking at them. HIPAA treats X-rays no differently from medical records in general, so whatever you are doing for your records - provided you are HIPAA-compliant there - should suffice for the X-rays as well.