This document discusses the need for small to medium sized hospitals to implement an incident response plan and cyber incident response team (CIRT) to properly handle security incidents. It notes that most such organizations currently lack dedicated resources to properly address cybersecurity issues. The document then outlines some of the key legal implications of health data privacy laws and proposes adapting the established Incident Command System model used in emergency response to structure a CIRT. Specific recommendations are provided regarding the necessary skills, tools, and processes a CIRT would need to effectively prepare for, identify, contain, eradicate, recover from, and follow up on security incidents.