Enterprise imaging platform selection
PL-1 procedures require security/privacy planning deliverables in the project gate before contract signature and ePHI flow.
Planning Policy and Procedures
Medium Risk
Easy
Low Cost
PL-1 requires planning policy and procedures addressing purpose, scope, roles, management commitment, coordination, and compliance, plus procedures to implement the Planning family. In healthcare, PL-1 ensures system security/privacy plans, architecture decisions, and rules of behavior are governed — so EHR and related ePHI systems are not operated on undocumented tribal knowledge.
Control Objective
Establish policy and procedures that require coordinated security and privacy planning for systems and organizations handling ePHI, including plan maintenance and distribution controls.
Implementation Guidance
- Publish PL-1 policy requiring security/privacy plans for major ePHI systems and enterprise programs.
- Define plan owners, approvers, and review frequency.
- Require planning artifacts before authorization/go-live (link to CA-1).
- Address rules of behavior / acceptable use for workforce accessing ePHI.
- Protect planning documents that reveal architecture.
- Coordinate planning with risk assessment, contingency, and IR plans.
- Review PL-1 annually and after organizational restructuring.
- Align with PL-2 system plans and PL-4 rules of behavior.
Real-World Use Cases
How this control shows up in healthcare and HIPAA-covered environments.
Rules of behavior refresh
Policy mandates annual acknowledgment updates when telehealth and BYOD rules change.
M&A of a specialty clinic
Planning policy triggers integration security plans for absorbing clinic EHR interfaces.
Best Practices
- Planning required at project gates for ePHI systems.
- Named owners for each major plan.
- Annual review cadence.
- Controlled distribution of architecture-rich plans.
- Integrate privacy planning with security planning.
- Link to authorization decisions.
Common Gaps & Violations
- No enterprise planning policy; only ad-hoc SSPs.
- Plans created for audits then abandoned.
- Rules of behavior never acknowledged.
- Privacy omitted from system planning.
- Architecture diagrams on open shares.
Required Documentation
- Planning policy (PL-1)
- Procedures for plan development/review
- Roles for planners and approvers
- Rules of behavior governance
- Policy review records
How to Test & Validate
- Confirm PL-1 policy exists and is current.
- Sample a major ePHI system for planning artifacts required by policy.
- Verify review dates meet stated frequency.
- Check rules of behavior acknowledgment process.
- Inspect access controls on plan repositories.
Audit Considerations
Planning policy shows whether security/privacy is intentional. Assessors correlate missing PL-1 discipline with stale system plans and weak authorization stories.
HIPAA Mapping
How this NIST control supports HIPAA Security Rule expectations.
- 164.316 Policies and procedures — implement reasonable and appropriate policies; planning policy structures how safeguards are designed.
- 164.308(a)(1) Security Management Process — risk analysis/management feed planning.
- 164.530(i) Policies and procedures (Privacy Rule) — privacy policy framework complements security planning.
- 164.308(a)(8) Evaluation — evaluations rely on planned controls being documented.
Compliance Tips
- Add PL planning checklist to PMO templates for clinical IT projects.
- Store plans in a restricted GRC or controlled SharePoint library.
- Schedule combined security/privacy plan reviews annually.
Frequently Asked Questions
Is PL-1 the same as the HIPAA risk analysis?
No. Risk analysis informs plans; PL-1 requires governance for planning activities and artifacts such as system security/privacy plans.
Do small clinics need PL-1?
Yes at a scaled level — document how you plan safeguards for your EHR and related processes.
How does PL-1 relate to PL-2?
PL-1 is the policy; PL-2 produces system security and privacy plans under that policy.
References & Resources
- NIST SP 800-53 Rev. 5 — PL-1
- NIST SP 800-18
- Related controls: PL-2, PL-4, CA-2, RA-3, PM-1
Related Guidelines
Related controls that commonly accompany PL-1.
Need Help Implementing PL-1?
Our auditors map NIST SP 800-53 controls to your HIPAA Security Rule program — policies, technical evidence, and audit readiness.