164.308(a)(4)(i) Information Access Management (Standard)
Implement policies authorizing access to ePHI consistent with applicable HIPAA Privacy Rule requirements. NIST recommends minimum necessary, role-based, and least-privilege access.
4
artefacts
0
held by a system
1
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Access review reports · Identity provider / directory
governing documentDocuments that govern the control
- Access management policy · Policy repository / GRC workspace
- Role catalog · Policy repository / GRC workspace
- Minimum necessary determinations · Policy repository / GRC workspace
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- No minimum necessary analysis
- Roles overly broad
- Access reviews informal
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)(C) Termination Procedures (Addressable) · 164.308(a)(4)(ii)(A) Isolating Health Care Clearinghouse Functions (Required if applicable)