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Domain C: Information Access Management

Role-based access, unique user IDs, and the access-authorization paper trail.

Every item here is already part of the current, final HIPAA Security Rule. Items marked NPRM: would become Required are currently Addressable, OCR’s pending 2025 proposed rule would eliminate that flexibility and make them mandatory if finalized (not yet in effect).

Unique user ID assigned to every person accessing ePHI systems

Required

45 C.F.R. §164.312(a)(2)(i) · Source: www.ecfr.gov/current/title-45/section-164.312

Emergency access procedure documented and tested

Required

45 C.F.R. §164.312(a)(2)(ii) · Source: www.ecfr.gov/current/title-45/section-164.312

Health care clearinghouse functions isolated from larger organization systems (if applicable)

Required

45 C.F.R. §164.308(a)(4)(ii)(A) · Source: www.ecfr.gov/current/title-45/section-164.308

Access authorization decisions documented per role, tied to job function

AddressableNPRM: would become Required

45 C.F.R. §164.308(a)(4)(ii)(B) · Source: www.ecfr.gov/current/title-45/section-164.308

Access establishment and modification procedure

AddressableNPRM: would become Required

45 C.F.R. §164.308(a)(4)(ii)(C) · Source: www.ecfr.gov/current/title-45/section-164.308

Periodic access review performed on active accounts, not only at onboarding

AddressableNPRM: would become Required

45 C.F.R. §164.308(a)(4) · Source: www.ecfr.gov/current/title-45/section-164.308

Automatic session logoff configured on workstations and applications

AddressableNPRM: would become Required

45 C.F.R. §164.312(a)(2)(iii) · Source: www.ecfr.gov/current/title-45/section-164.312

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