Element

Access to client data requires a unique ID assigned to each user.

GV.PO-01: Policy for managing cybersecurity risks is established based on organizational context, cybersecurity strategy, and priorities and is communicated and enforced

GV.PO-02: Policy for managing cybersecurity risks is reviewed, updated, communicated, and enforced to reflect changes in requirements, threats, technology, and organizational mission

PR.DS-10: The confidentiality, integrity, and availability of data-in-use are protected

3rd Party Access Controls 2 - Are there procedures for terminating or changing 3rd party access when the BAA, contract, or relationship ends or changes?

Business Agreements 1 - Does the organization have a list of all business associates and vendors with access to ePHI, and is there a Business Agreement in place with each partner, contractor, and vendor that recognizes each party's responsibility for data protection?

Business Agreements 2 - Is there a Business Agreement in place with each partner, contractor, and vendor that ensures disclosure if the 3rd party experiences a cyber attack, data breach, of other security event?

3rd Party Access Controls 3 - Do the organization's Business Agreements clearly identify which vendors, partners, suppliers, 3rd party organizations will or may have access to ePHI, how they will use it, and their commitment to protecting it?

Business Agreements 3 - Do Business Associate Agreements (BAAs) describe how the businesses will communicate security/network/and interface technology changes and events to one another?

Business Agreements 4 - Does each BAA give assurance(s) that the partner or vendor will follow best practices and/or compliance to protect ePHI/PCI/PII?

Segmentation - Are there mechanisms in place to segment the organization's internal network from any shared network space occupied by vendors and partners?

How does the board monitor the organization's compliance with relevant cybersecurity regulations and standards? (Monitoring compliance with regulations)

How frequently does the board receive updates on the organization's current cyber threat landscape and potential vulnerabilities? (Frequency of threat landscape updates)

Change-control processes and procedures are followed for all changes to system components.