EvidenceSheet

164.308(a)(3)(ii)(A) Authorization and Supervision (Addressable)

Implement procedures for authorization and supervision of workforce members who work with ePHI. NIST recommends formal approval workflows and supervisory checks for sensitive functions.

4
artefacts
1
held by a system
1
at each review
moderate
to go live
Identity provider / directory
where the evidence lives
teal = a system already holds it · olive = produced at each review

system holds itEvidence a system already holds

  • Privileged action monitoring · Identity provider / directory

periodic reviewEvidence produced at each review

  • Supervisor sign-off records · Identity provider / directory

governing documentDocuments that govern the control

  • Access request and approval forms · Policy repository / GRC workspace
  • Workforce supervision policy · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (Identity provider / directory); 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)(3)(i) Workforce Security (Standard) · 164.308(a)(3)(ii)(B) Workforce Clearance Procedure (Addressable)