Practice Name:__________________________________________ Location: ___________________________ Date: _____________ HIPAA/HITECH Privacy & Security Facility Walkthrough Checklist This document is designed as a checklist that can be used to determine security risks on a walkthrough of a facility. The items in this checklist are derived from NIST SP 800-53 Recommended Security Controls for Federal Information Systems and Organizations. As such, the items in this checklist are neither required for HIPAA Compliance, nor guarantee HIPAA Compliance. However, this checklist can be useful to a health care provider for identifying physical security risks in the facility and can be used as part of an overall risk assessment. The entries in the ID column relate directly to the IDs found in the “Physical and Environmental Protection” section of SP 800-53 where more information and guidance can be found on the risks and remediation of said item. To use this checklist it is suggested that you: a) Print this document and carry on the walkthrough b) During walkthrough, place checkmarks or x’s in the Yes/No column c) Get additional information from facility staff member about items that are not visibly apparent or about policies and procedures controlling access to the facility d) Make any additional notes in the Notes column e) After walkthrough, fill out an electronic copy of the document and provide to the provider to be included with other Risk Assessment documentation Facility Walkthrough Checklist v1.0 Page 1 Practice Name:__________________________________________ Location: ___________________________ Date: _____________ ITEM YES/ NO ID CONTROL DESCRIPTION NOTES General Policies PE-1 Documented policies and procedures that address physical and environmental security Method to determine who is authorized to access secure area of the office (e.g. badges, swipe cards, biometrics) Physical Authorization PE-2 Inventory of Assets PE-3f Inventory of physical assets maintained. Delivery/Removal Records PE-16 The organization authorizes, monitors, and controls components containing EHR entering and exiting the facility. Alternate Work Site PE-17 The facility provides an alternate work site or remote access for employees in the event of an emergency. Visitors escorted PE-7 Visitors are authenticated and escorted or monitored at all times. Visitor records PE-8 Visitor access records exist containing name/organization, signature, form of ID, time of entry and departure, purpose of visit, and person visited. Access Authorization (Visitors) PE-3a PE-3b Access Authorization (Staff) PE-3a PE-3b Physical access authorization for visitor access to secure area of office (e.g. sign-in sheet, Photo ID verification, Photo in EHR) Physical access authorization for staff access to secure area of office (e.g. badges) Public Area Protected Appropriately PE-3d Secure Area Physically Protected PE-3c Facility Access Access to publicly-accessible area controlled in accordance with identified risk (e.g. receptionist able to monitor waiting room, after hours locks or alarm system) Access to secure access physically monitored or protected (e.g. receptionist monitors entry, locked door, or security camera) Facility Walkthrough Checklist v1.0 Page 2 Practice Name:__________________________________________ Location: ___________________________ Date: _____________ ITEM YES/ NO ID CONTROL DESCRIPTION Keys etc secured. PE-3e Keys, combinations, and passwords physically secured. Locks changed PE-3g Changes locks and keys when lost or stolen or staff termination. Monitors not visible PE-5(2) Secure systems with access to EHR PE18(2) Computer monitors are protected from visibility by unauthorized individuals (e.g. by situating in such a way that they are not visible or security filters on screens) Systems with access to EHR are protected by theft by physical location or anti-theft controls (e.g. cable locks) Output devices protected PE-5(1) Devices such as monitors, printers, and fax machines protected by physical access control. Network/phone cable protected PE-4 Power protected PE-9 Transmission lines are protected (e.g. wiring cabinet is locked, cables are protected by conduit, no access to cables in publicly accessible area) Power equipment and power cabling are protected from damage or destruction (e.g. redundant power, physical protection of cables) NOTES Physical Protections Emergency Systems Emergency power shut-off PE-10 Water shut-off valves PE-15 Emergency lighting PE-12 Ability to shut off power to the EHR in the event of an emergency and ability to shut off power from a safe location. Power shut off protected from unauthorized activation. The organization protects the information system from damage resulting from water leakage by providing master shutoff valves that are accessible, working properly, and known to key personnel. The organization employs and maintains automatic emergency lighting for the information system that activates in the event of a power outage or Facility Walkthrough Checklist v1.0 Page 3 Practice Name:__________________________________________ Location: ___________________________ Date: _____________ ITEM YES/ NO ID CONTROL DESCRIPTION NOTES disruption and that covers emergency exits and evacuation routes within the facility. Fire detectors and suppression. PE-13 The organization employs and maintains fire suppression and detection devices/systems for the information system that are supported by an independent energy source. EHR in secure location PE18(1) Doors locked/monitored to secure area PE18(3) The EHR system is positioned to minimize potential damage from environmental hazards such as flooding, fire, electrical interference, and theft. Physical entry points to secure area are protected from unauthorized entry. EHR systems monitored PE-6 Physical access to EHR systems is monitored. (e.g. access logs, cameras, alarms) Emergency power PE-11 Temp and Humidity Controlled PE-14 The organization provides a UPS to facilitate an orderly shutdown of the information system in the event of a primary power source loss. Maintains and monitors temperature and humidity controls within the area where the EHR resides. EHR System Notes: Facility Walkthrough Checklist v1.0 Page 4