164.310(b) Physical Safeguards

Media Controls

High Risk Moderate Implementation Medium Cost

Implement policies and procedures that govern the receipt and removal of hardware and electronic media that contain ePHI into and out of a facility, and the movement of these items within the facility.

Implementation Guidance

Develop comprehensive media control policies including:
• Media receipt and removal procedures
• Media movement and tracking procedures
• Media sanitization and disposal procedures
• Media inventory and management procedures
• Media security and protection procedures
• Media access control procedures

Key components:
- Media receipt and removal
- Media movement tracking
- Media sanitization
- Media inventory management
- Media security controls
- Media access controls

Required Documentation

• Media control policies and procedures
• Media receipt and removal procedures
• Media movement and tracking procedures
• Media sanitization and disposal procedures
• Media inventory and management procedures
• Media security and protection procedures
• Media access control procedures

Best Practices

• Develop comprehensive media control policies
• Implement effective media tracking
• Use proper media sanitization methods
• Maintain accurate media inventory
• Implement strong media security controls
• Control access to media
• Regular review and update of procedures

Common Violations

• Lack of media control policies
• Inadequate media tracking procedures
• Insufficient media sanitization
• Poor media inventory management
• Inadequate media security controls
• Insufficient media access controls

Testing Procedures

• Review media control policies
• Test media tracking procedures
• Verify media sanitization methods
• Review media inventory management
• Test media security controls
• Verify media access controls
• Review policy compliance

Audit Considerations

• Media control policies and procedures
• Media tracking implementation
• Media sanitization effectiveness
• Media inventory management
• Media security controls
• Media access controls
• Policy review and updates

NIST Cybersecurity Framework Alignment

This HIPAA control aligns with the following NIST Cybersecurity Framework functions and controls:

Identify (ID)

ID.AM-1: Physical devices and systems within the organization are inventoried
ID.AM-2: Software platforms and applications within the organization are inventoried
ID.AM-3: Organizational communication and data flows are mapped

Protect (PR)

PR.AC-1: Identities and credentials are issued, managed, verified, revoked, and audited
PR.AC-3: Remote access is managed
PR.DS-1: Data-at-rest is protected
PR.DS-2: Data-in-transit is protected

Detect (DE)

DE.AE-1: A baseline of network operations and expected data flows is established
DE.CM-1: The network is monitored to detect potential cybersecurity events
DE.CM-3: Personnel activity is monitored to detect potential cybersecurity events

Respond (RS)

RS.CO-1: Personnel know their roles and order of operations when a response is needed
RS.CO-2: Incidents are reported consistent with established criteria
RS.AN-1: Notifications from detection systems are investigated

Recover (RC)

RC.RP-1: Recovery plan is executed during or after a cybersecurity incident
RC.IM-1: Recovery plans incorporate lessons learned
RC.CO-1: Public relations are managed

Note: This mapping provides a general alignment between HIPAA controls and NIST Framework functions. Specific implementation may vary based on your organization's risk profile and compliance requirements.

Implementation Templates & Checklists

Download our expert-developed templates and checklists to implement this control effectively:

Implementation Checklist

Step-by-step checklist to ensure complete implementation of this control

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Policy Template

Ready-to-customize policy template for this specific control

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Risk Assessment Form

Comprehensive risk assessment form for this control

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Training Materials

Staff training materials and awareness resources

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Expert Implementation Recommendations

Based on our experience with 500+ healthcare organizations, here are our expert recommendations for implementing this control:

High Priority

Start with Risk Assessment

Conduct a comprehensive risk assessment to identify specific vulnerabilities and threats related to this control. This will help prioritize implementation efforts and allocate resources effectively.

Identify all systems and data covered by this control
Assess current security measures and gaps
Evaluate potential impact of security incidents
Document findings and remediation priorities

Medium Priority

Develop Comprehensive Policies

Create detailed policies and procedures that address all aspects of this control. Ensure policies are specific, actionable, and aligned with your organization's risk profile.

Define roles and responsibilities clearly
Establish approval workflows and escalation procedures
Include specific technical requirements and standards
Regular review and update schedules

Low Priority

Implement Monitoring and Testing

Establish ongoing monitoring and testing procedures to ensure the control remains effective over time. Regular testing helps identify new vulnerabilities and compliance gaps.

Automated monitoring where possible
Regular manual testing and validation
Incident response procedures
Continuous improvement processes

Recommended Implementation Timeline

Week 1-2: Assessment & Planning

Conduct risk assessment and develop implementation plan

Week 3-4: Policy Development

Create and review policies and procedures

Week 5-8: Implementation

Deploy technical controls and train staff

Week 9-10: Testing & Validation

Test controls and validate compliance

Related Controls

164.310(a)(1) - Facility Access Controls
164.310(a)(2) - Workstation Use
164.310(c) - Device and Media Controls
164.312(a)(1) - Access Control

Control ID: 164.310(b)

Category: Physical Safeguards

Subcategory: Media Controls

Risk Level: High

Difficulty: Moderate

Cost: Medium

Timeframe: 2-4 months

Last Updated: Nov 22, 2025