EvidenceSheet

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.

Source: HIPAA Security Rule, 164.308(a)(4)(ii)(A). 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
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. 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

  • 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

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)(4)(i) Information Access Management (Standard) · 164.308(a)(4)(ii)(B) Access Authorization (Addressable)