164.308(a)(5)(ii)(D) Password Management (Addressable)
Implement procedures for creating, changing, and safeguarding passwords. NIST recommends aligning to SP 800-63B authenticator assurance levels and considering multi-factor authentication for ePHI access.
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
- MFA deployment report · Identity provider / directory
- Breached password screening configuration · Identity provider / directory
periodic reviewEvidence produced at each review
- Password manager rollout records · Identity provider / directory
governing documentDocuments that govern the control
- Password policy aligned with NIST SP 800-63B · 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
- Forced rotation without compromise indicator
- No MFA for remote access to ePHI
- Shared accounts with static passwords
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)(5)(ii)(C) Log-in Monitoring (Addressable) · 164.308(a)(6)(i) Security Incident Procedures (Standard)