EvidenceSheet

164.312(c)(2) Mechanism to Authenticate ePHI (Addressable)

Implement electronic mechanisms to corroborate that ePHI has not been altered or destroyed in an unauthorized manner. NIST recommends hash-based or signed integrity verification.

Source: HIPAA Security Rule, 164.312(c)(2). 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.

Scope: Addressable, not optional: assess whether it is reasonable and appropriate; implement it, or document why not and adopt an equivalent alternative where reasonable (45 CFR 164.306(d)(3)).

Applies to covered entities and business associates. An addressable specification can be met by a documented, reasonable alternative.

4
artefacts
3
held by a system
0
at each review
easy
to go live
SIEM / log platform
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

  • Hash or signature verification configuration · Cloud console / configuration management
  • FIM alert investigation records · SIEM / log platform
  • Audit trail of integrity events · SIEM / log platform

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

  • Documented addressable-specification decision: whether it is reasonable and appropriate in your environment, and if not, why, with the equivalent alternative adopted where one is · Policy repository / GRC workspace

First move

Automate the pull from your SIEM / log platform. Retention and alert rules exported from the SIEM; review evidence is the closed-alert record with reviewer and time.

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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164.312(c)(1) Integrity (Standard) · 164.312(d) Person or Entity Authentication (Standard)