| Administrative Safeguards |
| Administrative Safeguards |
HIPAA security risk assessment |
Administrative |
Verify that a formal risk assessment is completed, documented, and reviewed regularly. |
Missing risk assessments can leave PHI-related threats unidentified. |
9 |
Needs Review |
|
|
Perform and document a full HIPAA risk assessment. |
|
| Administrative Safeguards |
HIPAA policies and procedures |
Administrative |
Review written policies for access control, acceptable use, remote access, incident response, retention, and disposal. |
Outdated or missing policies create compliance and operational gaps. |
8 |
Needs Review |
|
|
Update and approve written HIPAA security policies. |
|
| Administrative Safeguards |
Assigned HIPAA Security Officer |
Administrative |
Confirm a responsible person is assigned to oversee HIPAA security requirements. |
Lack of ownership can result in unmanaged risk and poor accountability. |
6 |
Needs Review |
|
|
Assign and document HIPAA security responsibility. |
|
| Administrative Safeguards |
Business Associate Agreements |
Administrative |
Confirm vendors handling PHI have signed and current BAAs. |
Vendors without BAAs may expose the organization to compliance liability. |
8 |
Needs Review |
|
|
Review vendor list and obtain missing BAAs. |
|
| User Awareness and Workforce Security |
| User Awareness |
HIPAA security awareness training |
Administrative |
Verify all workforce members receive HIPAA and cybersecurity awareness training. |
Untrained users increase phishing, ransomware, and PHI disclosure risk. |
8 |
Needs Review |
|
|
Implement recurring HIPAA and cybersecurity training. |
|
| User Awareness |
Phishing and ransomware awareness |
Administrative / Technical |
Review phishing simulations, security reminders, and ransomware response education. |
Phishing is a common entry point for credential theft and ransomware. |
8 |
Needs Review |
|
|
Deploy phishing awareness program and periodic simulations. |
|
| Workforce Security |
User access termination process |
Administrative / Technical |
Verify terminated employees lose access immediately across systems. |
Former employees may retain access to PHI or sensitive systems. |
9 |
Needs Review |
|
|
Create offboarding checklist and access removal workflow. |
|
| Workforce Security |
Role-based access control |
Administrative / Technical |
Confirm access to PHI is based on job role and minimum necessary access. |
Excessive permissions increase breach impact and insider risk. |
8 |
Needs Review |
|
|
Review permissions and remove unnecessary access. |
|
| Technical Safeguards |
| Technical Safeguards |
Unique user accounts |
Technical |
Confirm shared accounts are not used for systems containing PHI. |
Shared accounts reduce accountability and weaken audit trails. |
6 |
Needs Review |
|
|
Create unique user IDs for all users. |
|
| Technical Safeguards |
Multi-factor authentication |
Technical |
Review MFA coverage for email, EHR, VPN, cloud systems, admin portals, and remote access. |
Missing MFA increases account takeover and PHI exposure risk. |
10 |
Needs Review |
|
|
Enable MFA for all sensitive and remote access systems. |
|
| Technical Safeguards |
Audit logging and monitoring |
Technical |
Verify logs capture PHI access, authentication events, administrator activity, and suspicious behavior. |
Without logs, incidents may go undetected and investigations may fail. |
9 |
Needs Review |
|
|
Enable centralized logging and routine log review. |
|
| Technical Safeguards |
Endpoint protection |
Technical |
Review antivirus, EDR, patching, disk encryption, and mobile device controls. |
Unprotected endpoints may lead to malware, ransomware, or PHI theft. |
8 |
Needs Review |
|
|
Deploy endpoint security and verify device compliance. |
|
| Network Infrastructure Security |
| Network Security |
Firewall configuration review |
Technical |
Review firewall rules, exposed services, remote access, and unnecessary inbound/outbound traffic. |
Misconfigured firewalls can expose PHI systems to attackers. |
9 |
Needs Review |
|
|
Review, document, and harden firewall rules. |
|
| Network Security |
Network segmentation |
Technical |
Confirm sensitive systems, guest Wi-Fi, servers, endpoints, and PHI systems are properly segmented. |
Flat networks increase ransomware spread and unauthorized PHI access. |
8 |
Needs Review |
|
|
Segment networks and restrict lateral movement. |
|
| Network Security |
Vulnerability scanning |
Technical |
Verify internal and external vulnerability scans are performed and tracked. |
Unpatched vulnerabilities may be exploited to access PHI systems. |
8 |
Needs Review |
|
|
Run recurring scans and remediate critical findings. |
|
| Network Security |
Secure remote access |
Technical |
Review VPN, remote desktop, cloud access, MFA, and remote user device security. |
Weak remote access can allow unauthorized entry into PHI environments. |
9 |
Needs Review |
|
|
Secure remote access with MFA, VPN, and access restrictions. |
|
| PHI Data Security |
| PHI Security |
Data at rest encryption |
Technical |
Review encryption for databases, servers, laptops, cloud storage, file shares, and backups. |
Unencrypted stored PHI may be exposed after theft or compromise. |
9 |
Needs Review |
|
|
Enable encryption for systems storing PHI. |
|
| PHI Security |
Data in transit encryption |
Technical |
Verify PHI is encrypted through email, portals, APIs, VPN, HTTPS, SFTP, and file transfers. |
Unencrypted transmission may expose PHI to interception. |
9 |
Needs Review |
|
|
Use TLS, encrypted email, secure portals, SFTP, or VPN. |
|
| PHI Security |
PHI access review |
Administrative / Technical |
Review who can access PHI and whether access aligns with job responsibilities. |
Improper access increases privacy and breach risk. |
8 |
Needs Review |
|
|
Perform periodic access reviews and remove excessive permissions. |
|
| PHI Security |
Data retention policy |
Administrative |
Verify retention periods are defined for medical, billing, backup, archive, and operational records. |
Improper retention may create legal, compliance, and data exposure risks. |
6 |
Needs Review |
|
|
Document retention requirements and implement retention controls. |
|
| PHI Security |
Secure data disposal |
Administrative / Physical / Technical |
Review shredding, media sanitization, device wiping, and destruction records. |
Improper disposal can expose PHI after equipment or document disposal. |
8 |
Needs Review |
|
|
Implement secure disposal and maintain destruction logs. |
|
| Backup and Disaster Recovery |
| Backup and Recovery |
Regular PHI backup process |
Administrative / Technical |
Verify critical PHI systems are backed up on a defined schedule. |
Missing backups may prevent recovery after ransomware or system failure. |
10 |
Needs Review |
|
|
Implement documented backup schedules for PHI systems. |
|
| Backup and Recovery |
Backup encryption |
Technical |
Confirm backup data is encrypted at rest and during transfer. |
Unencrypted backups may expose large volumes of PHI. |
9 |
Needs Review |
|
|
Encrypt all backup storage and backup transmission. |
|
| Backup and Recovery |
Backup restoration testing |
Administrative / Technical |
Review evidence that backups are tested and recoverable. |
Untested backups may fail during an emergency. |
9 |
Needs Review |
|
|
Schedule and document regular restore tests. |
|
| Backup and Recovery |
Disaster recovery plan |
Administrative |
Confirm recovery objectives, emergency operations, responsibilities, and procedures are documented. |
Poor disaster recovery planning can affect PHI availability and business continuity. |
8 |
Needs Review |
|
|
Create and test a documented disaster recovery plan. |
|
| Physical Safeguards |
| Physical Safeguards |
Facility access controls |
Physical |
Review locks, badge access, visitor procedures, cameras, and restricted areas. |
Unauthorized physical access can expose systems, devices, and paper PHI. |
6 |
Needs Review |
|
|
Strengthen facility access and visitor control procedures. |
|
| Physical Safeguards |
Workstation security |
Physical / Technical |
Verify screen locks, monitor positioning, physical access restrictions, and workstation use controls. |
Unsecured workstations may expose PHI to unauthorized viewing or access. |
6 |
Needs Review |
|
|
Implement workstation security standards and automatic screen locks. |
|
| Physical Safeguards |
Device and media inventory |
Physical / Administrative |
Review asset inventory for laptops, servers, drives, mobile devices, and removable media. |
Untracked devices may contain PHI and be lost, stolen, or improperly disposed. |
7 |
Needs Review |
|
|
Maintain updated asset inventory and device ownership records. |
|
| Incident Response and Breach Management |
| Incident Response |
Incident response plan |
Administrative |
Verify the organization has a documented incident response plan and escalation process. |
Delayed or disorganized response can worsen breach impact and notification risk. |
8 |
Needs Review |
|
|
Create or update incident response procedures. |
|
| Incident Response |
Breach notification process |
Administrative |
Review breach investigation, documentation, notification, and legal escalation procedures. |
Poor breach handling may create regulatory, legal, and reputational damage. |
8 |
Needs Review |
|
|
Define breach notification workflow and responsible parties. |
|
| Incident Response |
Tabletop exercises |
Administrative |
Confirm incident response exercises are performed and documented. |
Untested response plans may fail during real security incidents. |
6 |
Needs Review |
|
|
Conduct ransomware and PHI breach tabletop exercises. |
|
| Third-Party and Vendor Security |
| Vendor Security |
Vendor risk assessment |
Administrative |
Review security posture of MSPs, cloud providers, billing vendors, EHR vendors, and SaaS providers. |
Weak vendor security can create indirect PHI exposure. |
8 |
Needs Review |
|
|
Assess vendor security and document findings. |
|
| Vendor Security |
Third-party access review |
Administrative / Technical |
Review vendor remote access, admin permissions, support accounts, and logging. |
Uncontrolled vendor access can lead to unauthorized PHI access. |
9 |
Needs Review |
|
|
Limit, monitor, and document all third-party access. |
|
| OCsecurityAudit Professional Assessment Support |
| Professional Support |
HIPAA compliance consultation |
Administrative / Technical / Physical |
Engage experienced security professionals to review HIPAA readiness and identify security gaps. |
Organizations may overlook technical or administrative gaps without an independent review. |
7 |
Optional |
OCsecurityAudit |
Ali Hassani, CISSP and CISO-certified expert with 25+ years of experience. |
Contact OCsecurityAudit for a free HIPAA compliance consultation. |
|