164.312(d) Person or Entity Authentication (Standard)
Implement procedures to verify that a person or entity seeking access to ePHI is the one claimed. NIST recommends multi-factor authentication and authenticator assurance levels per SP 800-63B.
4
artefacts
2
held by a system
0
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
- Federation and SSO design · Identity provider / directory
periodic reviewEvidence produced at each review
none for this control
governing documentDocuments that govern the control
- Authentication standard aligned to NIST SP 800-63B · Policy repository / GRC workspace
- Service account authentication design · 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
- No MFA on ePHI access
- Weak factor combinations
- Service-to-service authentication uses static secrets
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 sheet164.312(c)(2) Mechanism to Authenticate ePHI (Addressable) · 164.312(e)(1) Transmission Security (Standard)