Information Access Management
Implement policies and procedures for authorizing access to ePHI that are consistent with the applicable requirements of the Security Rule.
Implementation Guidance
• Access authorization procedures
• Access establishment and modification procedures
• Access review and recertification processes
• Emergency access procedures
• Access termination procedures
• Documentation of access decisions
Key requirements:
- Isolating healthcare clearinghouse functions
- Access authorization based on job functions
- Regular access reviews and updates
- Emergency access procedures
- Proper documentation of all access decisions
Required Documentation
• Access authorization procedures
• Access establishment and modification procedures
• Access review and recertification procedures
• Emergency access procedures
• Access termination procedures
• Documentation of access decisions
• Regular review and update procedures
Best Practices
• Regular access reviews and recertification
• Document all access decisions and rationale
• Implement emergency access procedures
• Use automated access management tools
• Regular training on access management
• Monitor and audit access regularly
Common Violations
• Failure to implement regular access reviews
• Lack of emergency access procedures
• Insufficient documentation of access decisions
• Failure to isolate healthcare clearinghouse functions
• Inadequate access termination procedures
Testing Procedures
• Test access authorization processes
• Verify access review and recertification procedures
• Test emergency access procedures
• Review access termination procedures
• Verify documentation of access decisions
• Test monitoring and auditing capabilities
Implementation Resources
Download expert-developed templates and checklists to implement this control:
Quick Facts
Related Controls
Explore other controls in the Administrative Safeguards category.
Contingency Plan
Establish (and implement as needed) policies and procedures for responding to an emergency or other occurrence (for example, fire, vandalism, system f...
Security Awareness and Training
Implement a security awareness and training program for all members of the workforce (including management)....
Evaluation
Perform a periodic technical and non-technical evaluation, based initially upon the standards implemented under this rule and subsequently, in respons...
Need Help Implementing This Control?
Our certified HIPAA experts can help you implement this control correctly and efficiently.