164.308(b)(1) Business Associate Contracts and Other Arrangements (Standard)
A covered entity may permit a business associate to handle ePHI only after obtaining satisfactory assurances via written contract. NIST recommends due diligence, security questionnaires, and ongoing monitoring of BAs.
4
artefacts
1
held by a system
1
at each review
moderate
to go live
SIEM / log platform
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- Ongoing monitoring records · SIEM / log platform
periodic reviewEvidence produced at each review
- Vendor risk assessments · Vendor register / contract repository
governing documentDocuments that govern the control
- BA inventory · Vendor register / contract repository
- Executed BAAs · Vendor register / contract repository
First move
Start with the 1 of 4 artefacts that already live in a system (SIEM / log platform); keep the periodic reviews but log each one as a dated record with a named reviewer.
Common gaps auditors find
- BA inventory incomplete
- BAAs missing for cloud vendors
- No ongoing monitoring after onboarding
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)(8) Evaluation (Standard) · 164.308(b)(2) Subcontractor Arrangements