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Components of HIPAA Security Policy Template

 

Table 1 provides a brief summary of the objective of each security policy and associated procedures. Note that all HIPAA Security Rule categories (sections) are identified in color rows, standards are identified in bold and implementation specifications are shown as regular text.
HIPAA Security Policy/Procedure
Description

Administrative Safeguards

Security Management Process The purpose is to implement policies and procedures to prevent, detect, contain, and correct security violations.
Risk Analysis The purpose is to conduct an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of electronic protected health information.
Risk Management The purpose is to implement security measures sufficient to reduce risks and vulnerabilities to a reasonable and appropriate level.
Sanction Policy The purpose is to apply appropriate sanctions against workforce members who fail to comply with the security policies and procedures of the organization.
Information System Activity Review The purpose is to implement procedures to regularly review records of information system activity, such as audit logs, access reports, and security incident tracking reports.
Assigned Security Responsibility The purpose is to identify the security official who is responsible for the development and implementation of the HIPAA security policies and procedures.
Workforce Security The purpose is to implement policies and procedures to ensure that all members of the workforce have appropriate access to electronic protected health information and to prevent those workforce members who do not have access from obtaining access to electronic protected health information.
Authorization and/or Supervision The purpose is to implement procedures for the authorization and/or supervision of workforce members who work with electronic protected health information or in locations where it might be accessed.
Workforce Clearance Procedure The purpose is to implement procedures to determine that the access of a workforce member to electronic protected health information is appropriate.
Termination Procedures The purpose is to implement procedures for terminating access to electronic protected health information when the employment of a workforce member ends.
Information Access Management The purpose is to implement policies and procedures for authorizing access to electronic protected health information.
Access Authorization The purpose is to implement policies and procedures for granting access to electronic protected health information, for example, through access to a workstation, transaction, program, process, or other mechanism.
Access Establishment and Modification The purpose is to implement policies and procedures that, based upon the entity’s access authorization policies, establish, document, review, and modify a user’s right of access to a workstation, transaction, program, or process.
Security Awareness and Training The purpose is to implement a security awareness and training program for all members of its workforce, including management.
Security Reminders The purpose is to provide periodic security updates to members of the workforce.
Protection from Malicious Software The purpose is to develop procedures for guarding against, detecting, and reporting malicious software.
Log-in Monitoring The purpose is to develop procedures for monitoring log-in attempts and reporting discrepancies.
Password Management The purpose of this policy is to establish a standard for creation of strong passwords, the protection of passwords, and the frequency of change.
Security Incident Procedures The purpose is to implement policies and procedures to address security incidents.
Response and Reporting The purpose is to identify and respond to suspected or known security incidents; mitigate, to the extent practicable, harmful effects of security incidents that are known to the covered entity; and document security incidents and their outcomes.
Contingency Plan The purpose is to establish (and implement as needed) policies and procedures for responding to an emergency or other occurrence (for example, fire, vandalism, system failure, and natural disaster) that damages systems that contain electronic protected health information.
Data Backup Plan The purpose is to establish and implement procedures to create and maintain retrievable exact copies of electronic protected health information.
Disaster Recovery Plan The purpose is to establish (and implement as needed) procedures to restore any loss of data.
Emergency Mode Operation Plan The purpose is to establish and implement as needed procedures to enable continuation of critical business processes for protection of the security of electronic protected health information while operating in emergency mode.
Testing and Revision Procedures The purpose is to implement procedures for periodic testing and revision of contingency plans.
Applications and Data Criticality Analysis The purpose is to assess the relative criticality of specific applications and data in support of other contingency plan components.
Evaluation

The purpose is to perform a periodic technical and non-technical evaluation, based initially upon the standards implemented under this rule and subsequently, in response to environmental or operational changes affecting the security of electronic protected health information, which establishes the extent to which an entity's security policies and procedures meet the requirements of the HIPAA Security Rule.

Business Associate Contracts and Other Arrangements The purpose is to establish a contract that may permit a business associate to create, receive, maintain, or transmit electronic protected health information on the covered entity’s behalf only if the covered entity obtains satisfactory assurances that the business associate will appropriately safeguard the information.
Physical Safeguards
Facility Access Controls The purpose is to implement policies and procedures to limit physical access to its electronic information systems and the facility or facilities in which they are housed, while ensuring that properly authorized access is allowed.
Contingency Operations The purpose is to establish and implement as needed procedures that allow facility access in support of restoration of lost data under the disaster recovery plan and emergency mode operations plan in the event of an emergency.
Facility Security Plan The purpose is to implement policies and procedures to safeguard the facility and the equipment therein from unauthorized physical access, tampering, and theft.
Access Control and Validation Procedures The purpose is to implement procedures to control and validate a person’s access to facilities based on their role or function, including visitor control, and control of access to software programs for testing and revision.
Maintenance Records The purpose is to implement policies and procedures to document repairs and modifications to the physical components of a facility which are related to security (for example, hardware, walls, doors, and locks).
Workstation Use The purpose is to implement policies and procedures that specify the proper functions to be performed, the manner in which those functions are to be performed, and the physical attributes of the surroundings of a specific workstation or class of workstation that can access electronic protected health information.
Workstation Security The purpose is to implement physical safeguards for all workstations that access electronic protected health information and restrict access to authorized users only.
Device and Media Controls The purpose is to implement policies and procedures that govern the receipt and removal of hardware and electronic media that contain electronic protected health information into and out of a facility, and the movement of these items within the facility.
Disposal The purpose is to implement policies and procedures to address the final disposition of electronic protected health information, and/or the hardware or electronic media on which it is stored.
Media Re-use The purpose is to implement procedures for removal of electronic protected health information from electronic media before the media are made available for re-use.
Accountability The purpose is to maintain a record of the movements of hardware and electronic media and any person responsible therefore.
Data Backup and Storage The purpose is to create a retrievable, exact copy of electronic protected health information, when needed, before movement of equipment.
Technical Safeguards
Access Control The purpose is to implement technical policies and procedures for electronic information systems that maintain electronic protected health information to allow access only to those persons or software programs that have been granted access rights.
Unique User Identification The purpose is to assign a unique name and/or number for identifying and tracking user identity.
Emergency Access Procedure The purpose is to establish (and implement as needed) procedures for obtaining necessary electronic protected health information during an emergency.
Automatic Logoff The purpose is to implement electronic procedures that terminate an electronic session after a predetermined time of inactivity.
Encryption and Decryption The purpose is to implement a mechanism to encrypt and decrypt electronic protected health information.
Audit Controls The purpose is to implement hardware, software, and/or procedural mechanisms that record and examine activity in information systems that contain or use electronic protected health information.
Integrity The purpose is to implement policies and procedures to protect electronic protected health information from improper alteration or destruction.
Mechanism to Authenticate Electronic Protected Health Information The purpose is to implement electronic mechanisms to corroborate that electronic protected health information has not been altered or destroyed in an unauthorized manner.
Person or Entity Authentication
The purpose is to implement procedures to verify that a person or entity seeking access to electronic protected health information is the one claimed.

Transmission Security

The purpose is to implement technical security measures to guard against unauthorized access to electronic protected health information that is being transmitted over an electronic communications network.

Integrity Controls

The purpose is to implement security measures to ensure that electronically transmitted electronic protected health information is not improperly modified without detection until disposed of.
Encryption
The purpose is to implement a mechanism to encrypt electronic protected health information whenever deemed appropriate.
Organizational Framework
Policies and Procedures The purpose is to implement reasonable and appropriate policies and procedures to comply with the standards, implementation specifications and other requirements of the HIPAA Security Rule.
Documentation The purpose is to maintain the policies and procedures implemented to comply with the HIPAA Security Rule in written (or electronic) form and if an action, activity or assessment is required to maintain a written (which may be electronic) record.
Other Policies 
Information Classification The purpose is to address information classification categories, acceptable access and use of information such as e-PHI and other sensitive information.
Network Security The purpose is to establish requirements for information processed by computer networks.
Email Security The purpose is to establish management direction, procedures, and requirements to ensure safe and successful delivery of e-mail.
Wireless Security
The purpose is to implement security measures sufficient to reduce risks and vulnerabilities of the wireless infrastructure.
VPN Security
The purpose is to implement security measures sufficient to reduce the risks and vulnerabilities of the VPN infrastructure.
Remote Access
The purpose is to implement security measures sufficient to reduce risks and vulnerabilities of remote access connections to the enterprise infrastructure.
Dial-in Access
The purpose is to implement security measures sufficient to reduce risks and vulnerabilities of dial-in connections to the enterprise infrastructure.
Table 1: HIPAA Academy InfoSec Policies and Procedures

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Last updated: November 20, 2004