164.308(a)(3)(ii)(C) Termination Procedures (Addressable)
Implement procedures for terminating access to ePHI when employment ends or as required. NIST recommends time-bounded SLA, asset recovery, and HR-IT coordination.
4
artefacts
1
held by a system
2
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
system holds itEvidence a system already holds
- Termination audit log · SIEM / log platform
periodic reviewEvidence produced at each review
- Account disablement SLA evidence · Identity provider / directory
- Asset return records · HR system / LMS
governing documentDocuments that govern the control
- Termination checklist · HR system / LMS
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
- Accounts active days after termination
- Mobile devices not recovered
- Cloud SaaS accounts overlooked
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.
Build my evidence sheet164.308(a)(3)(ii)(B) Workforce Clearance Procedure (Addressable) · 164.308(a)(4)(i) Information Access Management (Standard)