Executive summary. Audit controls earn their keep when the events can be interpreted, retained, protected, and reviewed by someone accountable.
Definition
HIPAA Security Rule audit controls are hardware, software, or procedural mechanisms that record and examine activity in information systems containing or using ePHI.
Log the access and decisions that matter
Prioritize events that answer who accessed which category of data, from where, under what authority, and what significant action followed. Raw technical logs are often necessary and rarely sufficient for an investigation.
Protect log integrity and set retention against legal, security, and operational needs. A log an administrator can quietly alter carries less evidentiary weight than one that cannot be changed after the fact.
Reviewing is the other half
Define the review frequency, triggers, escalation, owner, and evidence of completion. An anomaly that produces an alert but no disposition record is still an open question.
Design searches around investigations: user, object, time window, organization, action, reason. Reviewers can then answer a question without exporting unnecessary PHI.
Frequently asked questions
Must every database read be logged?
HIPAA is scalable and does not prescribe one event schema. Design on risk, and make sure meaningful activity in systems that use ePHI can be examined.
Referenced standards and further reading
- 45 CFR 164.312(b), Audit controls ↗Electronic Code of Federal Regulations
Related articles
HIPAA Security Rule risk analysis: scope, evidence, decisions →
The minimum necessary standard in operational design →
Business associate relationships: map the work, not the logo →