HIPAA Technical Safeguards Requirements: What They Are and How to Comply

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HIPAA Technical Safeguards Requirements: What They Are and How to Comply

Kevin Henry

HIPAA

February 16, 2024

7 minutes read
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HIPAA Technical Safeguards Requirements: What They Are and How to Comply

HIPAA technical safeguards define the technology and related processes you must implement to protect electronic protected health information (ePHI). This guide explains each safeguard, how to operationalize it, and the evidence you should keep to demonstrate compliance.

Below, you’ll find practical steps for access control, audit controls, integrity, authentication, and transmission security, followed by risk assessment and documentation practices that tie everything together.

Implement Access Control

Access control ensures only authorized users, applications, and devices can view or modify ePHI. Your goal is to grant the least privilege required, track “who did what,” and prevent unauthorized use even if credentials leak.

Core elements to implement

  • Unique user identification: assign a distinct ID to every human and service account; never share logins.
  • Emergency (“break-glass”) access: predefined, auditable procedures to reach ePHI during emergencies.
  • Automatic logoff and session management: enforce idle timeouts and re-authentication on sensitive actions.
  • Encryption and decryption mechanisms for data at rest, aligned to strong encryption standards.

How to comply in practice

  • Design role-based or attribute-based access (RBAC/ABAC) and map roles to job duties and data scopes.
  • Provision users via an identity platform (SSO) with lifecycle automation for joiners, movers, and leavers.
  • Enforce strong passwords or passphrases and prohibit shared or generic accounts.
  • Use least-privilege defaults, time-bound elevated access, and approval workflows for exceptions.
  • Set session timeouts by risk; require re-authentication before viewing or exporting large ePHI datasets.
  • Encrypt storage where ePHI resides (e.g., databases, backups) using modern, validated encryption standards.

Establish Audit Controls

Audit controls create an audit trail of activity in systems that create, access, transmit, or store ePHI. You must be able to reconstruct security-relevant events, detect anomalies, and prove appropriate oversight.

What to capture

  • User and service logins, authentication failures, and privilege escalations.
  • Access to ePHI records (view, create, update, delete, export) and bulk queries.
  • Administrative changes to security settings, policies, keys, and audit configurations.
  • Data transmissions carrying ePHI, including destination and cryptographic status.

How to comply in practice

  • Centralize logs in a secure SIEM; make logs tamper-evident and restrict access.
  • Synchronize time across systems (e.g., NTP) to ensure event correlation.
  • Define retention periods aligned to legal, contractual, and investigative needs.
  • Automate alerting for suspicious activity; review dashboards and exception reports routinely.
  • Test your audit trail by performing sample investigations and documenting the outcomes.

Ensure Integrity Controls

Integrity controls protect ePHI from improper alteration or destruction. You should detect unauthorized changes and prove that records remain complete and accurate over time.

Technical measures

  • Cryptographic checks (e.g., hashes, digital signatures) to verify data integrity end-to-end.
  • Application-level validation, database constraints, and versioning for clinical records.
  • Write-once or immutable storage for logs, backups, and finalized documents.
  • File integrity monitoring on servers and critical application paths.

How to comply in practice

  • Define integrity requirements per system and data type; document acceptable controls.
  • Automate change detection with alerts and periodic reconciliation against baselines.
  • Back up ePHI regularly, encrypt backups, and test restores to confirm data fidelity.
  • Record integrity incidents, impact, and remediation steps in your incident log.

Verify Person or Entity Authentication

Authentication confirms the identity of a person or entity before granting access to ePHI. Strong, layered authentication reduces account compromise risk and strengthens nonrepudiation.

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Authentication protocols and methods

  • Standards-based SSO (SAML or OpenID Connect) and OAuth 2.0 for applications and APIs.
  • Multi-factor authentication for privileged and remote access, and where risk is high.
  • Mutual TLS, SSH keys, or client certificates for service-to-service and administrative access.
  • Device authentication (certificates or posture checks) before allowing access to ePHI.

How to comply in practice

  • Enforce MFA by policy; restrict fallback to vetted exceptions with compensating controls.
  • Harden password policies, rotation for secrets, and rapid revocation on termination.
  • Monitor authentication events for anomalies, excessive failures, or atypical geolocation.
  • Document all authentication protocols in a standard and test them during access reviews.

Apply Transmission Security

Transmission security protects ePHI as it moves across networks. You must apply transmission encryption and integrity controls so data remains confidential and unaltered in transit.

Preferred encryption standards and controls

  • TLS 1.2 or higher (ideally TLS 1.3) with strong cipher suites for web, APIs, and mobile apps.
  • Mutual TLS or IPsec VPN for system-to-system connectivity and remote administration.
  • Secure email using enforced TLS; use S/MIME or PGP when end-to-end protection is required.
  • SSH for administrative access; disable legacy and weak protocols and ciphers.

How to comply in practice

  • Force HTTPS, enable HSTS, and block cleartext protocols that could expose ePHI.
  • Rotate and monitor certificates; pin where appropriate to reduce impersonation risk.
  • Protect telemetry and backups in transit between data centers and cloud regions.
  • Log transmission details to your audit trail, including encryption status and endpoints.

Conduct Risk Assessments

Risk analysis is the foundation of your HIPAA security program. You identify where ePHI lives and flows, evaluate threats and vulnerabilities, estimate likelihood and impact, and decide how to reduce risk to acceptable levels.

A practical risk analysis workflow

  • Inventory systems, vendors, and data flows that handle ePHI; diagram interfaces.
  • Identify threats (e.g., ransomware, insider misuse) and vulnerabilities (e.g., misconfigurations).
  • Assess current controls; rate likelihood and impact; calculate risk levels.
  • Prioritize remediation; assign owners, budgets, and deadlines; track to closure.
  • Reassess after significant changes, incidents, or new regulations.

Evidence to retain

  • Risk register, treatment plans, and acceptance justifications.
  • Testing artifacts for controls (e.g., encryption, authentication, logging).
  • Management approvals and periodic review notes.

Document Compliance Policies

Written policies and procedures demonstrate intent, guide daily operations, and provide proof during audits. Keep them clear, role-specific, and synchronized with real-world workflows and tools.

Policies and records to maintain

  • Access management, authentication, and authorization standards (including unique user identification).
  • Audit logging and monitoring procedures, including retention and review cadence.
  • Encryption standards for data at rest and in transit, key management, and rotation.
  • Change management, incident response, backup/restore, and disaster recovery procedures.
  • Training, sanctions, business associate agreements, risk analysis reports, and attestation records.

Conclusion

By applying strong access control, complete audit trails, integrity safeguards, robust authentication protocols, and transmission encryption—backed by ongoing risk analysis and clear documentation—you build a defensible, operational HIPAA program that protects patients and scales with your organization.

FAQs

What are the key HIPAA technical safeguards?

The core safeguards are access controls, audit controls, integrity controls, person or entity authentication, and transmission security. Together they ensure only authorized access to ePHI, create an audit trail of activity, prevent improper alteration, verify identity, and protect data in transit with encryption and integrity checks.

How do you implement audit controls under HIPAA?

Log security-relevant events across all ePHI systems, centralize them in a protected SIEM, and make logs tamper-evident. Capture logins, record access, administrative changes, and transmissions; retain logs per policy; review exceptions regularly; and test your ability to reconstruct incidents using the audit trail.

What methods ensure transmission security for ePHI?

Use TLS 1.2+ (prefer TLS 1.3) for web, APIs, and mobile; mutual TLS or IPsec for system links; SSH for admin access; and enforced TLS for email, with S/MIME or PGP for end-to-end protection when needed. Manage certificates, disable weak protocols, and monitor transmission encryption as part of routine operations.

How often should risk assessments be conducted for HIPAA compliance?

Perform a comprehensive risk analysis at least annually and whenever you introduce major system changes, onboard new vendors, experience incidents, or modify workflows that handle ePHI. Update the risk register, reprioritize remediation, and keep management approvals and review notes as evidence of continuous compliance.

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