Technical safeguards

The HIPAA technical safeguards requirement means you must implement technical controls that protect ePHI through access controls, audit controls, integrity controls, and transmission protections across every system that creates, receives, maintains, or transmits ePHI ¹. Operationalize it by mapping ePHI data flows, enforcing unique user IDs and least-privilege access, turning on audit logs, protecting data integrity, and encrypting ePHI in transit with evidence that the controls work.

Key takeaways:

• Scope first: inventory every ePHI system and data flow so safeguards apply everywhere ePHI touches.
• Build four control pillars: access, audit logging, integrity, and transmission security for ePHI.
• Evidence wins exams: keep configurations, screenshots/exports, procedures, and log samples that prove ongoing operation.

“Technical safeguards” is the part of the HIPAA Security Rule that examiners expect to see translated into concrete, system-level controls. The requirement is straightforward in concept: protect electronic protected health information (ePHI) with access controls, audit controls, integrity protections, and transmission safeguards ¹. The hard part is execution across modern environments where ePHI moves between EHRs, billing platforms, cloud storage, endpoints, email, integration middleware, and third parties.

A practical implementation approach starts with scoping: identify the systems and workflows that handle ePHI, including third-party hosted applications and managed services. Then apply a consistent technical baseline: unique user identities, strong authentication, least privilege, logging with review, integrity validation and change controls, and encrypted transmission. Finally, collect evidence in a form auditors can consume quickly: system settings, access reviews, log exports, and written procedures that match reality.

This page gives requirement-level guidance you can hand to IT, Security, and application owners and then track to closure in your GRC program. It prioritizes what to do, how to prove it, and where teams usually fail.

Regulatory text

Requirement (excerpt): “Apply access, audit, integrity, and transmission safeguards for ePHI.” ¹

What the operator must do: implement technical controls that (1) restrict ePHI access to authorized users and processes, (2) record and retain activity sufficient to examine access and actions affecting ePHI, (3) protect ePHI from improper alteration or destruction, and (4) protect ePHI during electronic transmission ¹.

Plain-English interpretation (what “good” looks like)

If a workforce member, system account, or third party touches ePHI, you should be able to answer four questions with proof:

1. Who can access ePHI, and why? (Access controls)
2. What did they do, and when? (Audit controls)
3. Can ePHI be altered without detection? (Integrity controls)
4. Can ePHI be read or modified in transit? (Transmission safeguards)

Your documentation must match operations. A policy that says “encryption is required” does not satisfy the technical safeguards requirement unless you can show encryption is actually enabled where ePHI transmits ¹.

Who it applies to

In-scope entities

• Covered Entities and Business Associates ¹

In-scope operational contexts (practical scoping)

Apply the technical safeguards requirement anywhere ePHI is created, received, maintained, or transmitted, including:

• EHR/EMR systems, practice management, billing/claims platforms
• File shares, cloud storage, collaboration tools used for clinical/admin workflows
• Email systems, patient communications platforms, call center/CRM systems if they contain ePHI
• Endpoints (laptops, virtual desktops) and mobile devices that access ePHI
• APIs/interfaces (HL7/FHIR gateways, integration platforms)
• Third-party hosted systems and managed services that store or process ePHI

A common scoping failure is treating “hosted by a third party” as out of scope. If you are the Covered Entity or Business Associate, you still need technical safeguards and oversight evidence for those environments ¹.

What you actually need to do (step-by-step)

Step 1: Build an ePHI system and data-flow map (your control “boundary”)

1. Inventory applications, databases, storage locations, endpoints, and integrations that touch ePHI.
2. For each, document: owner, environment (on-prem/cloud), where ePHI enters/exits, authentication method, and logging capability.
3. Identify third parties involved in hosting, support, transmission, or processing.

Output you want: a living system register and a simple data-flow diagram for major ePHI pathways. This becomes your control coverage map.

Step 2: Implement access controls (identity, authentication, authorization)

Implement controls that make access intentional and attributable:

1. Unique user IDs: prohibit shared accounts for workforce users; tightly control service accounts.
2. Least privilege: role-based access tied to job functions; remove default admin rights.
3. Strong authentication: enforce appropriate authentication for ePHI systems, including remote access and privileged access.
4. Provisioning/deprovisioning: access granted only after approval; terminate access promptly at offboarding; review access periodically.
5. Emergency access process: define who can break-glass, under what conditions, and how it is logged and reviewed.

Third-party angle: require third parties who administer systems with ePHI to use named accounts and MFA, and restrict access paths (VPN, bastion, PAM) with logging.

Step 3: Implement audit controls (logging, retention, and review)

Logging without review often fails in audits because it does not show detection capability.

1. Enable audit logging for: logins, failed logins, privilege changes, access to ePHI records, exports, and administrative actions (where supported).
2. Centralize logs where feasible (SIEM or managed log platform) and protect them from tampering.
3. Define log retention that supports investigations and operational needs.
4. Implement a review process: alerts for high-risk events (privileged access, bulk export, unusual access patterns) and a periodic human review with ticketed follow-up.

What auditors ask: “Show me evidence you review logs and escalate anomalies.” Keep samples ready.

Step 4: Implement integrity controls (prevent/detect improper alteration)

Integrity safeguards usually require a mix of application, system, and process controls:

1. Use access permissions to prevent unauthorized edits or deletions of ePHI.
2. Enable database/application integrity features available in your EHR and supporting systems (audit trails, record versioning, checksums where applicable).
3. Control changes to systems that store/process ePHI with change management: approvals, testing, and rollback plans.
4. Protect backups: immutable or otherwise protected from unauthorized modification, and test restore procedures.

Practical test: can you demonstrate who changed a record, what changed, and when? If not, strengthen audit trails and role permissions.

Step 5: Implement transmission safeguards (protect ePHI in transit)

1. Require encrypted transport for ePHI transfers (e.g., TLS for web/app traffic) and disable insecure protocols.
2. Secure remote access (VPN or equivalent) with strong authentication and device controls.
3. For email workflows involving ePHI, use secure messaging or enforced encryption methods supported by your environment.
4. Validate third-party connections: APIs, SFTP, interface engines. Require secure ciphers and key management processes.

Operational check: document the allowed methods for sending ePHI and block or monitor unapproved methods.

Step 6: Create “control-to-system” accountability

Assign an owner per system that handles ePHI and require them to attest (with evidence) that:

• access controls are configured and reviewed,
• audit logs are enabled and reviewed,
• integrity protections and change controls exist,
• transmission security is enforced.

Tools like Daydream fit here as the operational layer: assign controls to system owners, collect evidence on a schedule, and keep an audit-ready trail of approvals and exceptions without chasing screenshots over email.

Required evidence and artifacts to retain (audit-ready list)

Keep evidence tied to each in-scope system and to your overall program:

Access controls

• Access control policy and standards for ePHI systems ¹
• User access lists/role mappings for key ePHI applications
• Joiner/mover/leaver tickets showing approvals and removals
• Access review records (findings, removals, approvals)
• Service account inventory, purpose, and controls

Audit controls

• Logging configuration exports/screenshots per system
• SIEM/log platform configuration for key log sources
• Log review procedure and completed review records (tickets, analyst notes)
• Sample audit logs showing attributable user activity

Integrity controls

• Change management procedure for ePHI systems and infrastructure
• Change tickets for representative changes (approval, testing evidence)
• Application audit trail settings and sample outputs
• Backup configuration and restore test evidence

Transmission safeguards

• Network/security standards for encryption in transit
• TLS configurations or gateway settings (where applicable)
• Secure file transfer configuration (keys, permissions)
• Third-party connection security requirements and validation evidence

Common exam/audit questions and hangups (what to prepare for)

1. “Show me your ePHI systems.” Hangup: incomplete inventory, shadow IT, or unclear ownership.
2. “Can you prove access is least privilege?” Hangup: roles that are “close enough,” shared accounts, or stale access.
3. “Do you review logs, or just collect them?” Hangup: no defined review cadence, no documented follow-up, no samples.
4. “How do you prevent/spot improper changes to ePHI?” Hangup: weak audit trails in core apps; poor change control.
5. “How do you protect ePHI in transit to third parties?” Hangup: ad hoc SFTP accounts, email exceptions, unmanaged integrations.

Frequent implementation mistakes (and how to avoid them)

• Mistake: treating technical safeguards as an IT policy exercise.
  Fix: require per-system configuration evidence plus an owner attestation.

• Mistake: leaving shared or generic admin accounts in place.
  Fix: migrate to named admin accounts, restrict break-glass, and log all privileged sessions.

• Mistake: logging turned on, but nobody can find logs during an audit.
  Fix: document log locations, retention, and a simple “audit packet” with exports and screenshots.

• Mistake: encryption assumptions.
  Fix: verify actual transport security settings for each ePHI pathway (web, API, SFTP, remote access, email).

• Mistake: ignoring third-party administration access.
  Fix: require named accounts, MFA, restricted ingress paths, and logs for third-party activity.

Enforcement context and risk implications

No specific public enforcement cases were provided in the source data for this requirement, so this page does not summarize case outcomes. Practically, technical safeguards gaps increase the likelihood that an access incident becomes a reportable breach because you cannot demonstrate access was restricted, activity was logged, data integrity was preserved, or transmission was protected ¹.

Practical 30/60/90-day execution plan

Days 0–30: Scope, triage, and minimum viable controls

• Build the ePHI system inventory and identify “top risk” systems (EHR, file storage, remote access, email).
• Confirm unique IDs and disable shared accounts where feasible; document exceptions with compensating controls.
• Turn on audit logging for the most critical systems; centralize logs if already available.
• Validate encryption in transit for primary ePHI pathways (patient portals, remote access, interfaces).

Deliverables: ePHI system register, data-flow diagrams (high-level), initial evidence pack for critical systems.

Days 31–60: Standardize and operationalize

• Define access standards (roles, approvals, admin access, service accounts) and roll them out per system owner.
• Establish log review workflows with tickets, escalation paths, and documented outcomes.
• Implement change control requirements for ePHI systems and confirm audit trail settings in core applications.
• Lock down third-party access pathways and require attributable identities and MFA.

Deliverables: access review records, log review records, third-party access controls documented, change tickets sampled.

Days 61–90: Prove sustainment and close gaps

• Run an internal audit-style walkthrough: pick two systems and demonstrate end-to-end evidence for access, audit, integrity, and transmission safeguards.
• Close remaining gaps (legacy protocols, weak role design, missing logs).
• Formalize exception management with risk acceptance, compensating controls, and expiration dates.
• Move evidence collection to a repeatable cadence (system owner attestations plus automated evidence where possible).

Deliverables: audit-ready control narrative per system, exception register, recurring evidence schedule (tracked in Daydream or your GRC tool).

Frequently Asked Questions

What systems are “in scope” for the technical safeguards requirement?

Any system that creates, receives, maintains, or transmits ePHI is in scope, including third-party hosted applications you rely on ¹. Start with your EHR, identity provider, endpoints, email/messaging, file storage, and integration pathways.

Do we need encryption for every transmission of ePHI?

The requirement calls for transmission safeguards for ePHI ¹. Operationally, you should standardize approved secure methods for sending ePHI and block or tightly control unapproved pathways.

What’s the minimum audit logging evidence an auditor will accept?

Expect to show logging is enabled, protected, and reviewed. Keep configuration exports/screenshots, a written review procedure, and sample log review records with follow-up actions tied to tickets ¹.

How do we handle shared clinical workstations where multiple users access the same device?

Keep user attribution at the application and identity layer: named accounts for EHR access and strong session controls. If local OS accounts are shared for workflow reasons, document the rationale and compensating controls, and ensure ePHI access remains uniquely attributable in the ePHI system.

How should we manage service accounts for integrations that move ePHI?

Inventory them, document purpose and owner, restrict permissions, rotate secrets/keys under a controlled process, and log their activity where possible. Treat service account access as high risk because attribution is weaker than for named users.

Can Daydream help with this requirement without replacing our security tools?

Yes. Daydream can sit above your technical stack to assign ownership per ePHI system, track control implementation, collect evidence on a schedule, and maintain an audit trail of reviews and exceptions, while your SIEM/IAM/EHR controls do the actual enforcement.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control management

Footnotes

1. HIPAA Security Rule (45 CFR Part 164 Subpart C)