What Are HIPAA Audit Trail and Audit Log Requirements?

The HIPAA regulations describe a variety of security measures for receiving, storing, and sharing protected health information (PHI), and since HIPAA non-compliance can cost hospitals or private practices up to $50,000 it is important to learn about the healthcare regulations in advance to help avoid penalties.  

In this article, we are going to look at the audit trail and audit log compliance requirements that are a part of HIPAA and are outlined in the guidelines of the Department of Health and Human Services (HHS). 

In this article, you will be able to define and learn about the importance of HIPAA auditing requirements and how they can affect your healthcare organization.

Why Are HIPAA Logging Requirements so Important?

HIPAA logging requirements were developed to safeguard patients’ interests and help organizations do it the right way. While audit trails focus on how a certain event was performed, audit logs focus on the event itself and the user initiating it. Here are some of the reasons why logging requirements are so important:  

Boosting Patients’ Confidence in Your Institution

Patients are more likely to be more open about their medical conditions if they know that the disclosed information will be protected, as information from EHR or EMR could theoretically be used for blackmail against a patient. It’s also a target for hackers because such information is valued at up to $250 per record on the black market. Consequently, patients need to know that the healthcare institution tracks all the activities happening within their system and is able to provide the maximum security possible. 

Avoiding Hefty Fines

Secondly, non-compliance can get very expensive. If you do not have a good security system and thorough employee training there is a high chance that you will suffer data loss frequently.  

Memorial Healthcare System (MHS) paid a $5.5 million HIPAA settlement for violating audit control requirements. The credentials of one of their former employees were used for accessing the ePHI of 80,000 individuals for over a year. 

The total fine for HIPAA violations can go up to $1.5 million in a year and could even lead to criminal proceedings. Investment in security rules to ensure compliance can help avoid facing huge fines in the future, and by doing that save your organization tons of money.  

Avoiding Reputational Damage

Let’s not forget that the reputation of your healthcare organization is also very important. Patients care about their privacy and nowadays they have a variety of hospitals and practices to choose from. Statistics show that 31% of customers discontinue their relationships with an organization that was affected by a data breach, while 65% of customers lose trust in that organization. Overall, it is much cheaper to invest in HIPAA compliance than to lose patients and pay fines because you didn’t. 

What Are HIPAA Audit Trail Requirements?

Audit trails can tell what was done up to the current state of data. It allows the security personnel to quickly identify a data breach, track access, and maintain security standards. There are two main HIPAA trail requirements: 

Application Audit Trails

This focuses on logging the activities of a user. Healthcare institutions have to monitor and log all user activity: opening the data files connected to PHI, creating, reading, making changes, and closing them. This helps detect threats and assess if users’ actions may have caused harm to the files or overall system. 

System-Level Audit Trails

This focuses on monitoring the people who have logged in to the system. It also notes what device the user used and where they logged in from. Consequently, healthcare entities must monitor and log the following: successful and unsuccessful attempts of logins, IDs or usernames of those entering the system, time and date of each login, and devices from which the attempt was made.  

What Are HIPAA Audit Log Requirements?

Audit logs are focused on the who and the what. It helps to find the user who has compromised the files or system. There are two main HIPAA requirements applying to audit logs.  

Create Logs

One of the HIPAA requirements is role-based access to the ePHI environment. This ensures that users do not have access to all files automatically. Consequently, if a user tries to perform actions or gain access to the files that are above their position’s access level, the system knows to double-check who that user is. It may be an employee who violates confidentiality or an employee who got hacked. Logs help identify users and protect the system against potential issues and breaches. 

According to HIPAA log requirements, logs must contain the following information: 

• Every user attempt to login 
• Cases where changes to the file connected to PHI were made 
• Cases when new users were added 
• Access level of every user 
• Users that have access to the particular files 
• Firewall logs 
• Anti-malware logs 

Keep Logs For 6 Years

In most states, you have to keep logs for 6 years. However, some states have stricter requirements, and consequently longer time of log retention. You should check in with the requirements of your state before deciding whether or not to delete the files.  

While the reason for the existence of HIPAA audit log retention requirements is not well-known, it still plays an important role, as a lot of storage space is needed to keep a massive amount of data stored, which is exactly what it helps with. In short, retaining and analyzing all the stored data allows for the discovery of irregular patterns in the data. Every user has certain behavior in the system and the security personnel of your organization will start noticing these patterns over time. If there is even a slight difference in the data you will receive a notification immediately, and if there really is a breach you will be able to stop it very quickly.  

HIPAA log retention requirements are important in areas other than security. It allows transparency which the government can utilize to analyze and find fraud caused by employees themselves.  

Our Case

One of our clients is a premium provider of back-office solutions that serves over 300 healthcare organizations nationwide. As the complexity of operations grew, they needed a solution that would provide a unified view of the business and would correspond to the HIPAA audit trail and audit log requirements.  

We developed an enterprise-wide expandable web platform that tracks all the events happening within the system, records them, stores logs for 6 years, and alerts corresponding departments if any unusual behavior is detected. So basically, anything you need for a successful organization, we can make it. 

After implementing a solution developed by Langate, the client was able to minimize risks of data breach and ensure full compliance with legal requirements. Such improvements allowed the client to increase its customer base by 45%. 

Conclusion

Audit trails and logs are important for the early detection of data breaches and the tracing of the user or users responsible. They also add more transparency to healthcare institutions, allowing the government to review logs and find possible fraud.  

There are clear requirements to the information that should be logged, for example, all log-ins, activity, users, access levels. There is also an audit log retention requirement, which ensures you keep logs for at least 6 years. 

In order to ensure full compliance with the user audit trail and audit log requirements, it is better to consult with a company specialized in this matter. Our development center is HIPAA-compliant, and after more than 15 years of working in health tech, you can trust us to create secure solutions. Feel free to contact Langate and we’d be glad to work with you to ensure the compliance and success of your organization.