164.308(a)(4)(ii)(A) Isolating Health Care Clearinghouse Functions (Required if applicable)
If a clearinghouse is part of a larger organization, isolate ePHI from the larger organization. NIST recommends network segmentation and separate access domains.
4
artefacts
1
held by a system
0
at each review
moderate
to go live
Cloud console / configuration management
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- Firewall rules separating clearinghouse · Cloud console / configuration management
periodic reviewEvidence produced at each review
none for this control
governing documentDocuments that govern the control
- Network segmentation design · Policy repository / GRC workspace
- Clearinghouse isolation policy · Policy repository / GRC workspace
- Access boundary documentation · Policy repository / GRC workspace
First move
Start with the 1 of 4 artefacts that already live in a system (Cloud console / configuration management); keep the periodic reviews but log each one as a dated record with a named reviewer.
Common gaps auditors find
- Logical isolation incomplete
- Shared administrative accounts cross boundary
- No periodic isolation verification
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)(4)(i) Information Access Management (Standard) · 164.308(a)(4)(ii)(B) Access Authorization (Addressable)