164.310(a)(2) Physical Safeguards

Workstation Use

Medium Risk Moderate Implementation Medium Cost

Implement policies and procedures that specify the proper functions to be performed, the manner in which those functions are to be performed, and the physical attributes of the surroundings of a specific workstation or class of workstation that can access ePHI.

Implementation Guidance

Develop comprehensive workstation use policies including:
• Workstation use policies and procedures
• Physical security requirements for workstations
• Workstation configuration standards
• User responsibilities for workstation security
• Workstation monitoring and auditing procedures
• Workstation disposal and sanitization procedures

Key components:
- Workstation use policies
- Physical security requirements
- Configuration standards
- User responsibilities
- Monitoring and auditing
- Disposal procedures

Required Documentation

• Workstation use policies and procedures
• Physical security requirements
• Workstation configuration standards
• User responsibilities documentation
• Monitoring and auditing procedures
• Disposal and sanitization procedures
• Training materials and records

Best Practices

• Develop comprehensive workstation policies
• Implement physical security controls
• Establish configuration standards
• Provide user training and awareness
• Monitor workstation use regularly
• Implement proper disposal procedures
• Regular review and update of policies

Common Violations

• Lack of workstation use policies
• Inadequate physical security for workstations
• Insufficient workstation configuration standards
• Poor user training on workstation security
• Inadequate monitoring of workstation use
• Insufficient disposal procedures

Testing Procedures

• Review workstation use policies
• Test physical security controls
• Verify configuration standards
• Review user training records
• Test monitoring and auditing capabilities
• Verify disposal procedures
• Review policy compliance

Audit Considerations

• Workstation use policies and procedures
• Physical security implementation
• Configuration standards compliance
• User training and awareness
• Monitoring and auditing capabilities
• Disposal procedures
• 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

1

Week 1-2: Assessment & Planning

Conduct risk assessment and develop implementation plan

2

Week 3-4: Policy Development

Create and review policies and procedures

3

Week 5-8: Implementation

Deploy technical controls and train staff

4

Week 9-10: Testing & Validation

Test controls and validate compliance

Related Controls

164.310(a)(1) - Facility Access Controls
164.310(a)(2)(ii) - Workstation Controls
164.310(b) - Media Controls
164.312(a)(1) - Access Control