EvidenceSheet
HIPAA Security Rule · Organizational

164.314(a)(1) Business Associate Contracts or Other Arrangements (Standard)

The contract or other arrangement required by 164.308(b)(3) must meet the requirements of paragraph (a)(2)(i), (a)(2)(ii), or (a)(2)(iii) of this section, as applicable.

8
artefacts
0
held by a system
2
at each review
hard
to go live
Document repository
where the evidence lives
teal = a system already holds it · olive = produced at each review

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

  • Legal review records for BAAs · Document repository
  • Termination provisions evidence · HR system / LMS

governing documentDocuments that govern the control

  • BAA template addressing all required 164.314(a)(2) elements · Document repository
  • Government arrangement documentation where applicable · Document repository
  • Special arrangement records (group health plan, plan sponsor) · Policy repository / GRC workspace
  • Subcontractor BAAs flowing down requirements · Document repository
  • Inventory of BAAs by type (BA, subcontractor, government) · Policy repository / GRC workspace
  • Procedures for negotiating BAA exceptions · Policy repository / GRC workspace

First move

This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.

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(e)(2)(ii) Encryption of Transmissions (Addressable) · 164.314(a)(2)(i) Business Associate Contract Required Provisions