Security operations and monitoring

The HITRUST security operations and monitoring requirement means you must run continuous security monitoring and incident detection across in-scope systems, with defined coverage, alert handling, investigation steps, and retained evidence. To operationalize it fast, document monitoring scope, centralize security logs/telemetry, define triage and escalation, test the workflow, and keep auditable records of daily operations. ¹

Key takeaways:

• Define monitoring coverage and investigation procedures before tuning tools; auditors look for scope and repeatability. ¹
• Continuous monitoring is only “real” if alerts are triaged, investigated, escalated, and evidenced with tickets and logs. ¹
• Evidence wins assessments: show telemetry sources, detection rules, response workflow, and proof the process runs consistently. ¹

Security operations and monitoring is one of the fastest ways an assessor can tell whether your security program exists on paper or in production. For HITRUST, the practical intent is straightforward: you need continuous monitoring and incident detection capabilities, operating day-to-day across the systems that store, process, or transmit sensitive healthcare data (and the supporting infrastructure and identity layers). ¹

For a Compliance Officer, CCO, or GRC lead, the work is less about buying a SIEM and more about making monitoring auditable: clear coverage boundaries, defined investigation procedures, consistent execution, and retained artifacts that prove the monitoring function is running and acted upon. ¹

This page gives requirement-level implementation guidance you can put in motion immediately: who must comply, the minimum operating model, step-by-step setup, the evidence package to retain, common audit questions, failure modes, and a 30/60/90-day plan to get to “assessment-ready” without boiling the ocean. References here rely on publicly available HITRUST framework overviews rather than licensed control text. ¹

Security operations and monitoring requirement (HITRUST): plain-English meaning

You are expected to operate continuous security monitoring and incident detection capabilities. ¹

In plain English, that means:

• You collect security-relevant telemetry (logs, alerts, events) from in-scope systems.
• You review and triage detections.
• You investigate suspicious activity using defined procedures.
• You escalate and respond through an incident process.
• You can prove all of the above with records.

A single dashboard is not compliance. Assessors typically want to see that monitoring is continuous as an operating practice, not sporadic or ad hoc, and that it meaningfully feeds incident detection. ¹

Regulatory text

Provided excerpt (summary-level, not licensed text): “Baseline implementation-intent summary derived from publicly available framework overviews; licensed standard text is not reproduced in this record.” ¹

Implementation-intent summary: “Operate continuous security monitoring and incident detection capabilities.” ¹

What the operator must do: build and run a security monitoring function with defined coverage and documented investigation procedures, then retain evidence that it runs consistently and produces actionable detections (alerts, investigations, and escalations). ¹

Who it applies to

Entity scope (typical):

• Healthcare organizations handling regulated or sensitive data.
• Service providers supporting healthcare customers, including cloud/SaaS and managed services that touch sensitive systems or data. ¹

Operational context (where auditors focus):

• Production environments and the management plane (admin consoles, IAM).
• Identity systems (SSO, MFA, privileged access).
• Network and endpoint layers that can show attacker behavior.
• Third-party services that provide security telemetry or host in-scope workloads.

If you outsource monitoring to an MSSP, the requirement still applies. You must govern the third party, define expectations, and retain evidence that the service operates for your environment.

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

The fastest path is to define the operating model first, then map tools to it.

Step 1: Define monitoring coverage (scope + “must see” telemetry)

Create a one-page Monitoring Coverage Matrix that lists:

• In-scope systems (apps, databases, cloud accounts, endpoints, network segments).
• Telemetry sources per system (audit logs, auth logs, admin activity, EDR alerts).
• Collection method (agent, API, syslog, cloud-native export).
• Owner (team accountable for onboarding and uptime).
• Retention location (central log store/SIEM) and access controls.

Minimum bar: auditors should be able to pick a critical system and see where its logs go and who reviews alerts. This aligns with the recommended control to define monitoring coverage and investigation procedures. ¹

Step 2: Centralize logging and alerts into a monitored queue

Stand up (or validate) a central place where detections land:

• SIEM, cloud-native SIEM, or equivalent centralized logging with alerting.
• Ticketing integration so alerts become trackable work items.
• Role-based access so monitoring data is restricted and audit-trailed.

Focus on completeness for critical sources before tuning advanced analytics. “All endpoints onboarded” is less important than “endpoints that matter are onboarded and monitored with evidence.”

Step 3: Define investigation procedures (playbooks that match your detections)

Write short, operator-grade procedures:

• Alert triage SOP: severity categories, response time targets you set internally, enrichment steps, close criteria, and documentation requirements.
• Investigation playbooks: for common detections (suspicious login, impossible travel, privileged role change, malware, exfil indicators).
• Escalation rules: when to page security leadership, when to involve IT, when to trigger the incident response plan.
• Evidence capture checklist: screenshots, log queries, affected assets, user/account, timeline, containment steps.

These procedures are where many programs fail: they have tools but no consistent investigative record. HITRUST expects operating capability, not just technology spend. ¹

Step 4: Operationalize “continuous” with an on-call and review routine

Define:

• A monitored queue (who watches it, when).
• After-hours coverage model (internal on-call or third-party SOC).
• Daily review expectations (what is checked, what is documented).
• Weekly tuning cadence for noisy rules, with documented approvals.

If you cannot staff 24/7 internally, document the coverage model you do have and how handoffs work. Then keep evidence the handoffs occur.

Step 5: Test the pipeline end-to-end (detection → ticket → investigation → closure)

Run controlled tests:

• Generate a sample suspicious event (test user, test endpoint, admin role change in a test tenant).
• Confirm logs are ingested.
• Confirm alert triggers.
• Confirm a ticket is created.
• Confirm analyst follows the playbook and attaches required evidence.

Keep the test record as audit support and repeat when major systems change.

Step 6: Govern third parties that affect monitoring

If any third party provides security tooling, SOC services, or hosts in-scope systems:

• Put monitoring and incident-notification responsibilities into contracts/SOWs.
• Require access to monitoring outputs relevant to your environment (reports, tickets, summaries).
• Confirm log access and retention responsibilities.

This is where Daydream can reduce friction: track which third parties provide monitoring coverage, what evidence they owe you, and whether you have current artifacts for assessment.

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

Keep artifacts that show design, operation, and coverage:

Design evidence

• Monitoring Coverage Matrix (system → telemetry → destination → owner).
• Security monitoring policy/standard (what is monitored, who responds).
• Triage SOP and investigation playbooks.
• Escalation matrix and incident criteria.

Operational evidence

• Samples of alerts with timestamps.
• Tickets/cases showing triage notes, investigation steps, and closure rationale.
• Analyst notes or case timelines (even brief, if consistent).
• Change records for detection rule updates and approvals.

Technical evidence

• SIEM/log platform configuration exports (as feasible).
• Log source onboarding proof (screenshots/config, agent deployment reports).
• Access control list for monitoring tools and logs.
• Retention settings evidence (configuration screenshots or admin exports).

Organize evidence by system and by time period so you can answer: “Show me how you detected and handled something last month.”

Common exam/audit questions and hangups

Assessors tend to probe for gaps between claims and reality:

1. “What is in scope for monitoring?”
   Hangup: you describe “the SIEM” but cannot enumerate covered systems.

2. “Show an alert and the investigation record.”
   Hangup: alerts exist, but there is no ticket, no notes, or no repeatable steps.

3. “Who reviews alerts and how do you ensure coverage?”
   Hangup: informal monitoring with no schedule, no on-call plan, no accountability.

4. “How do you tune noisy detections?”
   Hangup: rules are disabled without justification or change control.

5. “How do third parties participate in monitoring and incident detection?”
   Hangup: MSSP runs the SOC, but you cannot produce their case records or reports.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
“We collect logs” without stating which logs	Coverage can’t be verified	Maintain a Coverage Matrix tied to your asset/system inventory
Alerts close with “false positive” and no analysis	Looks like checkbox operations	Require minimum investigation notes and closure criteria
Monitoring excludes identity/admin layers	High-risk activity goes unseen	Prioritize IAM, privileged actions, cloud control-plane logs
No consistent ticketing	No chain of custody	Force alerts into a case system with required fields
MSSP evidence is unavailable	You can’t prove operation	Contract for evidence, request periodic case samples

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not list specific cases. Operationally, weak security operations and monitoring increases the likelihood that security events are detected late, investigated inconsistently, or cannot be reconstructed during an incident. That becomes a business risk (outage duration, investigation cost, customer trust) and a compliance risk (assessment findings due to insufficient evidence of control operation). ¹

Practical 30/60/90-day execution plan

This plan is designed for a GRC lead coordinating Security and IT, with limited appetite for re-platforming.

First 30 days: define scope and make monitoring auditable

• Build the Monitoring Coverage Matrix for critical systems and identity layers.
• Document triage SOP, escalation rules, and minimum evidence standards for a closed alert.
• Confirm where alerts land and how they become tickets.
• Pull a small sample of recent alerts and confirm you can show a complete investigation record.

Deliverables: coverage matrix v1, SOP/playbooks v1, sample alert-to-ticket evidence set. ¹

Days 31–60: close coverage gaps and prove repeatable operations

• Onboard missing high-risk log sources (cloud control plane, IAM, EDR, critical apps).
• Standardize ticket fields (severity, timeline, hypothesis, evidence links, closure reason).
• Establish a weekly detection tuning and review meeting with documented outputs.
• Run an end-to-end test and retain results.

Deliverables: expanded coverage, operating cadence, tuning/change records, test evidence. ¹

Days 61–90: harden governance and prep for assessment

• Formalize third-party monitoring responsibilities (MSSP, cloud provider artifacts, SOC reporting).
• Create an “assessment binder” folder structure that maps artifacts to monitoring coverage.
• Run a tabletop focused on monitoring-to-incident escalation.
• Validate access controls for monitoring data and document approvals.

Deliverables: third-party evidence plan, assessment-ready artifact library, escalation test/tabletop record. ¹

Frequently Asked Questions

What counts as “continuous” monitoring for the security operations and monitoring requirement?

HITRUST’s intent is an ongoing capability to monitor and detect incidents, not occasional reviews. In practice, define your alert review coverage model, document it, and keep evidence that alerts are triaged and investigated consistently. ¹

Do we need a SIEM to meet this requirement?

A SIEM is a common way to centralize logs and alerts, but the requirement is about operating monitoring and incident detection. If you use other platforms, you still need defined coverage, investigation procedures, and retained evidence of operation. ¹

If an MSSP runs our SOC, are we covered?

You can outsource operations, but you cannot outsource accountability. Contract for access to case records or equivalent evidence, define escalation into your incident process, and retain artifacts that prove monitoring is happening for your environment. ¹

What evidence is the fastest to produce for an assessor?

Provide a monitoring coverage matrix plus a small set of closed alert tickets that include investigation notes and supporting log excerpts. Pair that with your triage SOP so the assessor can see the process is repeatable. ¹

How do we handle “noisy” alerts without failing an audit?

Treat tuning as controlled change: document why the rule is noisy, what change you made (threshold, suppression, scope), who approved it, and what you will monitor after the change. Keep those change records alongside detection content. ¹

How does Daydream help operationalize this requirement?

Daydream can track monitoring coverage by system and third party, assign evidence owners, and keep an audit-ready library of SOPs, tickets, and validation tests. That reduces the scramble to prove continuous operation during a HITRUST assessment. ¹

Related compliance topics

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

Footnotes

1. HITRUST certification overview