164.312(a)(1) Access Control (Standard)
Implement technical policies and procedures to allow only authorized persons or software programs access to ePHI. NIST recommends identity, authentication, authorization, and session management aligned to SP 800-53 AC fa
4
artefacts
1
held by a system
0
at each review
moderate
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
- Session management configuration · Identity provider / directory
periodic reviewEvidence produced at each review
none for this control
governing documentDocuments that govern the control
- Identity and access management design · Policy repository / GRC workspace
- Authentication standard · Policy repository / GRC workspace
- Authorization model · Policy repository / GRC workspace
First move
Start with the 1 of 4 artefacts that already live in a system (Identity provider / directory); keep the periodic reviews but log each one as a dated record with a named reviewer.
Common gaps auditors find
- Shared accounts in production
- Session timeouts not enforced
- Privileged access not isolated
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 sheet164.310(d)(2)(iv) Data Backup and Storage (Addressable) · 164.312(a)(2)(i) Unique User Identification (Required)