Administrative safeguards

The nine administrative safeguard standards in 45 CFR 164.308 and their implementation specifications: risk analysis and management, workforce and access management, training, incident response, contingency planning, evaluation and business associate assurances.

164.308(a)(1) Security management process

The umbrella administrative standard that requires policies and procedures to prevent, detect, contain and correct security violations, and anchors the four required specifications: risk analysis, risk management, sanction policy and information system activity review.

164.308(a)(1)(ii)(A) Risk analysis

The required risk analysis: an accurate and thorough assessment of risks and vulnerabilities to all ePHI. Covers what OCR expects a risk analysis to contain, the free HHS SRA Tool, and why OCR's Risk Analysis Initiative makes this the most enforced specification.

164.308(a)(1)(ii)(B) Risk management

The required follow-through on the risk analysis: implementing security measures that bring identified risks and vulnerabilities down to a reasonable and appropriate level, and the risk management plan OCR expects to see.

164.308(a)(1)(ii)(C) Sanction policy

The required sanction policy: applying appropriate sanctions to workforce members who fail to follow security policies and procedures, and how to document and apply it consistently.

164.308(a)(2) Assigned security responsibility

The standard that requires naming one security official responsible for developing and implementing the Security Rule policies and procedures. It has no separate implementation specifications.

164.308(a)(3) Workforce security

The standard for making sure every workforce member has appropriate access to ePHI and that those without authorized access cannot obtain it. Parent of three addressable specifications: authorization and supervision, clearance, and termination.

164.308(a)(3)(ii)(C) Termination procedures

Addressable procedures for removing access to ePHI when someone leaves or their arrangement ends, or when a clearance determination says access should stop. Covers offboarding evidence and timing.

164.308(a)(4) Information access management

The standard for authorizing access to ePHI in line with the Privacy Rule's minimum necessary approach. Parent of one required specification (isolating clearinghouse functions) and two addressable ones (access authorization, establishment and modification).

164.308(a)(4)(ii)(B) Access authorization

Addressable policies and procedures for granting access to ePHI, for example through access to a workstation, transaction, program or process. Defines who approves access and on what basis.

164.308(a)(5) Security awareness and training

The standard requiring a security awareness and training program for the whole workforce, including management. Parent of four addressable specifications: reminders, malware protection, log-in monitoring and password management.

164.308(a)(5)(ii)(C) Log-in monitoring

Addressable procedures for monitoring log-in attempts and reporting discrepancies, such as repeated failed log-ins. Distinct from broader activity review because it targets authentication events.

164.308(a)(5)(ii)(D) Password management

Addressable procedures for creating, changing and safeguarding passwords. The current rule does not set a password length or rotation interval, so the risk analysis decides.

164.308(a)(6) Security incident procedures

The standard and its single required specification, response and reporting: identifying and responding to suspected or known security incidents, mitigating harmful effects, and documenting incidents and outcomes.

164.308(a)(7) Contingency plan

The standard for responding to emergencies such as fire, vandalism, system failure or natural disaster that damage systems holding ePHI. Parent of three required plans (backup, disaster recovery, emergency mode) and two addressable activities.

164.308(a)(7)(ii)(A) Data backup plan

The required procedures to create and maintain retrievable exact copies of ePHI. Covers what must be backed up, how retrievability is shown, and how it relates to the device-level backup in 164.310(d).

164.308(a)(7)(ii)(C) Emergency mode operation plan

The required procedures that keep critical business processes running, while protecting ePHI, during an emergency. Different from disaster recovery: it covers operating during the event, not restoring afterward.

164.308(a)(8) Evaluation

The standard requiring periodic technical and nontechnical evaluation of how well security policies and procedures meet the Security Rule, first against the rule and then after environmental or operational changes. The closest the rule comes to an audit.

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