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RA-1(1) Risk Assessment

Reviews and Updates

Medium Risk Easy Low Cost

RA-1(1) (Reviews and Updates) enhances base RA-1 within the NIST Risk Assessment family. Base RA-1 sets the foundational expectation; this enhancement adds specificity: This enhancement strengthens RA-1 with requirements for reviews and updates in environments that create, receive, maintain, or transmit ePHI. Covered entities and business associates apply it to risk analysis, vulnerability scanning, and threat-informed prioritization for systems that create or store ePHI.

Control Objective

Implement Reviews and Updates so organization-defined risk assessment safeguards operate consistently on systems and networks that handle ePHI, with measurable evidence for HIPAA and NIST assessments.

Implementation Guidance

  1. Map RA-1(1) to systems in scope (EHR, imaging, lab, pharmacy, billing, identity, backups, and BA connections).\n2. Translate “Reviews and Updates” into technical settings, procedures, or architecture patterns owned by named roles.\n3. Prefer enforceable controls (config, automation, mediation) over awareness-only measures where feasible.\n4. Integrate with change, incident, and downtime processes so clinical operations are not surprised.\n5. Log and retain evidence of operation (tickets, configs, test results) aligned to audit needs.\n6. Include vendors/BAs in contracts and connection standards when they touch the control surface.\n7. Test after major EHR, network, or cloud changes — upgrades often reset protections.\n8. Review exceptions at least quarterly; expire “temporary” holes that expose ePHI paths.

Real-World Use Cases

How this control shows up in healthcare and HIPAA-covered environments.

Real-world scenario

Risk control “Reviews and Updates” (RA-1(1))\nRisk management implements Reviews and Updates so threats to ePHI are identified and treated. Evidence labeled for RA-1(1).\n\n### Board risk committee (RA-1(1))\nReviews and Updates outputs feed leadership risk decisions for clinical systems. Evidence labeled for RA-1(1).\n\n### BA risk input (RA-1(1))\nSupplier questionnaires support Reviews and Updates for services processing ePHI. Evidence labeled for RA-1(1).

Best Practices

  • Name an owner for RA-1(1) in the SSP control matrix.\n- Favor system enforcement on ePHI paths over informal email approval.\n- Measure coverage: percent of in-scope clinical systems where the enhancement operates.\n- Review exceptions quarterly with security and clinical informatics.\n- Feed relevant events to SIEM with a named use case.\n- Keep a one-page evidence pack (config + sample log + last test) ready for assessors.

Common Gaps & Violations

  • Policy cites RA-1(1) but production EHR/network paths show no enforcement of reviews and updates.\n- Permanent exceptions with no expiry for vendors or “special” clinics.\n- Control implemented only on corporate IT — clinical devices and interfaces omitted.\n- No logs or test records; reliance on tribal knowledge.\n- Major upgrade silently disabled the enhancement.

Required Documentation

  • Procedure/standard for Reviews and Updates (RA-1(1))\n- Architecture or configuration baselines showing enforcement points\n- Exception register with owners and expiry\n- Sample logs, alerts, or test results\n- Training or runbook references for clinical/IT operators

How to Test & Validate

  1. Attempt a prohibited or out-of-policy action related to reviews and updates; confirm block, alert, or required workflow.\n2. Complete an authorized clinical/IT path; confirm success and logging.\n3. Sample open exceptions for approval and expiry.\n4. Verify at least one EHR-adjacent and one BA/vendor path are in scope.\n5. Confirm evidence retained for the last 90 days (or per policy).

Audit Considerations

Assessors look for operating evidence of Reviews and Updates on systems touching ePHI — configs, logs, restore/DR artifacts, or failed-test results — not only a policy paragraph referencing RA-1(1).

HIPAA Mapping

How this NIST control supports HIPAA Security Rule expectations.

  • 164.308(a)(1)(ii)(A) Risk Analysis — accurate and thorough assessment of risks to ePHI.\n- 164.308(a)(1)(ii)(B) Risk Management — implement security measures sufficient to reduce risks.\n- 164.306(a) General requirements — protect against reasonably anticipated threats and hazards.\n- 164.308(a)(8) Evaluation — reassess when environmental or operational changes affect ePHI risk.

Compliance Tips

  • List RA-1(1) explicitly in the system security plan with system inventory references.\n- Prioritize emergency department, inpatient EHR, and remote access paths first.\n- Bundle evidence with related HIPAA evaluation, integrity, or workforce-security narratives where they overlap.

References & Resources

  • NIST SP 800-53 Rev. 5 — RA-1(1)\n- Related controls: RA-1\n- Note: RA-1(1) is retained in this knowledge base for coverage continuity; confirm applicability against your adopted baseline and current NIST catalog.

Related Guidelines

Related controls that commonly accompany RA-1(1).

RA-1 Critical

Risk Assessment Policy and Procedures

RA-1 requires risk assessment policy and procedures addressing purpose, scope, roles, management commitment, coordination, and compliance…
RA-2 High

Security Categorization

RA-2 requires categorizing the system and information it processes, storing categorization results with the system owner, and ensuring the…
RA-3 High

Risk Assessment

RA-3 requires conducting risk assessments that identify threats and vulnerabilities to operations, assets, individuals, and other…

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