164.308(a)(4)(ii)(B) Access Authorization (Addressable)
Implement policies for granting access to ePHI via workstation, transaction, program, or process. NIST recommends formal access request workflow with approval and provisioning records.
4
artefacts
2
held by a system
1
at each review
easy
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
- Provisioning logs · Identity provider / directory
- Role assignment audit trail · Identity provider / directory
periodic reviewEvidence produced at each review
- Approval records · Identity provider / directory
governing documentDocuments that govern the control
- Access request workflow tool · Policy repository / GRC workspace
First move
Automate the pull from your Identity provider / directory. Scheduled export of users, roles and MFA state from the directory; access-review completion pulled from the IdP, not a spreadsheet.
Common gaps auditors find
- Manual provisioning with no audit trail
- Approvals via informal channels
- No reconciliation of requests to grants
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)(ii)(A) Isolating Health Care Clearinghouse Functions (Required if applicable) · 164.308(a)(4)(ii)(C) Access Establishment and Modification (Addressable)