Unpatched VPN appliance
External scan finds a critical VPN CVE. RA-5 triage patches within 48 hours and verifies with a rescans — closing a common ransomware entry path.
Vulnerability Scanning
High Risk
Moderate
Medium Cost
RA-5 requires scanning for vulnerabilities in the system and hosted applications on a defined frequency and when new vulnerabilities potentially affecting the system are identified; employing scan tools that facilitate interoperability and automation; analyzing results; remediating legitimate vulnerabilities based on risk; and sharing results with designated personnel. Scans operationalize continuous discovery of weaknesses that threaten ePHI.
Control Objective
Discover, analyze, and drive remediation of technical vulnerabilities on systems that support ePHI before attackers exploit them.
Implementation Guidance
- Scope scanners across clinical, corporate, cloud, and internet-facing assets — maintain coverage maps.
- Prefer authenticated scanning for depth on servers and workstations.
- Scan on a defined cadence (e.g., weekly infrastructure, monthly apps) plus after major changes.
- Correlate CVE results with asset criticality (EHR > marketing site).
- SLAs for remediation by severity; track exceptions with risk acceptance.
- Feed results to SI-2 flaw remediation and RA-3 risk updates.
- Control scanner credentials as privileged secrets (IA-5).
- Include container/cloud posture and web app scanning where relevant.
Real-World Use Cases
How this control shows up in healthcare and HIPAA-covered environments.
Shadow clinical web server
Authenticated discovery finds an old IIS host with ePHI reports. It is patched or decommissioned and added to CM inventory.
EHR thick-client workstation fleet
Monthly authenticated scans show recurring Java vulnerabilities on nursing PCs; SI-2 packaging remediates at scale.
Best Practices
- Authenticated + external perspectives.
- Risk-based SLAs, not only CVSS blindly.
- Rescan to verify closure.
- Protect scanner service accounts.
- Integrate with ticketing.
- Exclude carefully — document unscanned gaps.
Common Gaps & Violations
- Occasional scan PDF with no remediation tracking.
- Critical clinical segments never scanned 'for fear of downtime.'
- No authenticated scans.
- Scanner creds over-privileged and shared.
- Findings never reach system owners.
Required Documentation
- Vulnerability management / scanning procedure
- Scan scope and schedule
- Remediation SLAs
- Recent scan reports and ticket samples
- Exception / risk-acceptance register
How to Test & Validate
- Confirm last scan dates for critical subnets meet schedule.
- Trace a critical finding to a closed ticket and clean rescan.
- Verify authenticated coverage on a sample server.
- Review exceptions older than policy allows.
- Confirm owners receive actionable reports.
Audit Considerations
Assessors look for ongoing scanning and closure evidence. A single annual scan without remediation fails RA-5 intent and weakens HIPAA risk management.
HIPAA Mapping
How this NIST control supports HIPAA Security Rule expectations.
- 164.308(a)(1)(ii)(A)–(B) Risk Analysis / Risk Management — vulnerability discovery feeds risk treatment.
- 164.308(a)(5)(ii)(B) Protection from Malicious Software — patching/scanning reduce malware footholds.
- 164.312(a)(1) Access Control — unpatched remote services undermine access control.
- 164.308(a)(8) Evaluation — technical evaluations often include vulnerability assessments.
Compliance Tips
- Publish severity SLAs everyone understands (e.g., critical internet-facing: 7 days).
- Never scan production clinical devices without a maintenance window and vendor guidance.
- Tie RA-5 dashboards into monthly security metrics for leadership.
Frequently Asked Questions
Does RA-5 require penetration testing?
RA-5 is vulnerability scanning. Penetration testing is often additional (e.g., CA-8) and valuable, but not a substitute for ongoing scanning.
Can we skip scanning medical devices?
Many need special handling; document compensating controls and vendor constraints — do not leave them invisible in the risk program.
How does RA-5 relate to SI-2?
RA-5 finds issues; SI-2 remediates flaws/patches on a controlled process.
References & Resources
- NIST SP 800-53 Rev. 5 — RA-5
- NIST SP 800-40 Guide to Enterprise Patch Management
- HIPAA § 164.308(a)(1)
- Related controls: SI-2, RA-3, CM-8, SI-4
Related Guidelines
Related controls that commonly accompany RA-5.
Need Help Implementing RA-5?
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