164.306 Security Standards: General Rules
Covered entities and business associates must ensure the confidentiality, integrity, and availability of all electronic protected health information (ePHI) they create, receive, maintain, or transmit; protect against reasonably anticipated threats; protect against reasonably anticipated impermissible uses or disclosures; and ensure workforce compliance. Entities may use flexibility of approach considering size, complexity, capabilities, technical infrastructure, costs, and probability and criticality of risks to ePHI.
Source: HIPAA Security Rule, 164.306. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open HIPAA Security Rule in the compliance library.
Applies to covered entities and business associates. An addressable specification can be met by a documented, reasonable alternative.
These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.
system holds itEvidence a system already holds
- Workforce compliance attestation records · Vendor register / contract repository
periodic reviewEvidence produced at each review
- Annual security program review minutes with executive sign-off · Policy repository / GRC workspace
governing documentDocuments that govern the control
- Information security program charter signed by executive leadership · Policy repository / GRC workspace
- Documented determination of covered entity vs. business associate status · Policy repository / GRC workspace
- EPHI inventory and data flow diagrams identifying creation, receipt, maintenance, transmission · Policy repository / GRC workspace
- Documented rationale for flexibility of approach decisions citing size, complexity, capabilities, costs, risk · Policy repository / GRC workspace
- Statement of applicability mapping security measures to CIA triad · Policy repository / GRC workspace
- Risk acceptance register for residual risks · Policy repository / GRC workspace
First move
Common gaps auditors find
- No documented justification for addressable specification decisions
- ePHI inventory incomplete or stale (missing SaaS, mobile, backup repositories)
- Flexibility decisions not tied back to risk analysis
- Workforce attestations expired or not collected for new hires
- No clear demarcation of covered entity vs. business associate functions
- Executive sign-off missing on security program documents
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
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