Health Information Management

HIPAA Q&A: You’ve got questions. We’ve got answers!

HIM-HIPAA Insider, February 9, 2015

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Submit your HIPAA questions to Editor Jaclyn Fitzgerald at jfitzgerald@hcpro.com and we will work with our experts to provide you with the information you need.

Q: As part of the audit controls policy at my organization, we hired an external security vendor to collect and review logs from several critical servers. The vendor creates tickets for our IT staff when a potential incident is discovered during the daily log review. This supplements our own activity reviews of internally generated reports, and the vendor then uses them for its own review. Our internal staff never sees the reports the vendor uses for its review. Do the reports the vendor uses fall under the HIPAA requirement for retaining logs for six years? Should we compel the vendor to retain these reports?
 
A: The short answer is yes. Covered entities (CE) need to maintain audit log reports for six years. If an external vendor is conducting the log review on behalf of a CE or an upstream business associate (BA), the CE or BA needs to request copies from the vendor or needs to ensure the contract with the vendor includes a requirement that log reports are retained for a minimum of six years.
 
Periodic review of the reports the vendor generates is another good idea. This extra due diligence ensures the vendor's assessment of an actionable incident is on the mark.
 
Editor’s note: Chris Apgar, CISSP, president of Apgar & Associates, LLC, in Portland, Oregon, answered this question for HCPro’s Briefings on HIPAA newsletter. This information does not constitute legal advice. Consult legal counsel for answers to specific privacy and security questions.



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