EvidenceSheet
HIPAA Security Rule · Administrative

164.308(a)(1)(ii)(C) Sanction Policy (Required)

Apply appropriate sanctions against workforce members who fail to comply with security policies. NIST recommends graduated sanctions, HR coordination, and documentation of each sanction action.

Source: HIPAA Security Rule, 164.308(a)(1)(ii)(C). 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.

4
artefacts
1
held by a system
1
at each review
moderate
to go live
SIEM / log platform
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

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

  • Sanction case log · SIEM / log platform

periodic reviewEvidence produced at each review

  • HR acknowledgement of policy · HR system / LMS

governing documentDocuments that govern the control

  • Sanction policy with graduated tiers · Policy repository / GRC workspace
  • Examples of sanctions applied · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (SIEM / log platform); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

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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164.308(a)(1)(ii)(B) Risk Management (Required) · 164.308(a)(1)(ii)(D) Information System Activity Review (Required)