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HIPAA Security Rule Controls List

The HIPAA Security Rule protects electronic health information held or sent by covered entities and their business associates. It groups its standards into administrative, physical and technical safeguards, and each standard is either required or addressable. This list covers the standards by safeguard.

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Who it is for. US healthcare providers, health plans and clearinghouses, and the business associates that handle electronic health information for them. That includes Indian IT, billing and outsourcing companies that work for US healthcare clients.

What this list covers. HIPAA Security Rule, 45 CFR 164.308 to 164.316: standards by safeguard: 20 standards. Each has a reference, a heading and a sentence in plain English.

Read it here, download it when you want it. The download is a CSV that opens in Excel or Google Sheets, with blank columns for whether each item applies to you, its status, owner and evidence, so you can use it as a working tracker.

Administrative safeguards. 45 CFR 164.308

RefControlWhat it requires
164.308(a)(1)Security management processAssess the risks to electronic health information, manage them, apply sanctions for breaches of policy and review activity records.
164.308(a)(2)Assigned security responsibilityName one person responsible for developing and running the security programme.
164.308(a)(3)Workforce securityMake sure staff have appropriate access, are cleared for it and lose it when they leave.
164.308(a)(4)Information access managementAuthorise access to health information in line with job roles, and set and review access rights.
164.308(a)(5)Security awareness and trainingTrain staff, give security reminders, and cover malware protection, login monitoring and password management.
164.308(a)(6)Security incident proceduresIdentify, respond to and document security incidents, and limit their harm.
164.308(a)(7)Contingency planKeep data backups, a disaster recovery plan and an emergency mode operation plan, and test them.
164.308(a)(8)EvaluationReview the security measures periodically, and when the environment or operations change.
164.308(b)Business associate contractsGet written assurances from every business associate that handles electronic health information for you.

Physical safeguards. 45 CFR 164.310

RefControlWhat it requires
164.310(a)Facility access controlsLimit physical access to systems and the buildings that hold them, with plans, validation and maintenance records.
164.310(b)Workstation useSpecify how workstations that touch health information may be used and what environment they sit in.
164.310(c)Workstation securityProtect workstations from unauthorised physical access.
164.310(d)Device and media controlsControl the receipt, movement, re-use and disposal of hardware and media that hold health information.

Technical safeguards. 45 CFR 164.312

RefControlWhat it requires
164.312(a)Access controlGive each user a unique identity, provide emergency access, log users off automatically and encrypt where reasonable.
164.312(b)Audit controlsRecord and examine activity in systems that contain or use health information.
164.312(c)IntegrityProtect health information from improper alteration or destruction, and be able to detect it.
164.312(d)Person or entity authenticationVerify that a person or system seeking access is who it claims to be.
164.312(e)Transmission securityGuard against unauthorised access to health information sent over a network, with integrity checks and encryption where reasonable.

Organizational requirements and documentation. 45 CFR 164.314 and 164.316

RefControlWhat it requires
164.314Organizational requirementsPut security terms into business associate contracts and into group health plan documents where they apply.
164.316Policies, procedures and documentationKeep written security policies and procedures, retain the documentation for six years and review it.
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A summary, not the source. The references and short headings identify each item. The wording beside them is our own summary and is not a quotation, a legal opinion or advice. Check the published source for the exact requirement. We help organisations with this: see our Cybersecurity Assessment service.

Questions people ask

What is the difference between required and addressable?

A required specification must be implemented. An addressable one must be assessed: implement it if reasonable and appropriate, or document why not and what you did instead. Addressable does not mean optional.

Does HIPAA apply to a company in India?

It can. An Indian company that creates, receives, maintains or sends electronic health information for a US covered entity is a business associate, and is bound by the Security Rule through its contract and directly under the regulation.

Is there a HIPAA certification?

No government body certifies HIPAA compliance. Vendors may show an independent assessment, but the legal duty is to meet the rule.

Does this cover breach notification?

No. Breach notification is a separate rule. In general, affected people must be told without unreasonable delay and within 60 days of discovery. Read the Breach Notification Rule for detail.

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