$npx -y skills add briiirussell/cybersecurity-skills --skill hipaa-auditAudit applications and infrastructure handling Protected Health Information against HIPAA — Security Rule (administrative, physical, technical safeguards), Privacy Rule, Breach Notification Rule, plus HITECH. Covers ePHI scoping, the 18 HIPAA identifiers, Business Associate Agree
| 1 | # HIPAA Audit — Health Insurance Portability and Accountability Act |
| 2 | |
| 3 | HIPAA governs how Protected Health Information (PHI) is handled in the United States healthcare ecosystem. The engineering surface area is large because PHI is broader than people often realize: a calendar entry naming a patient's appointment is PHI; an IP address logged on a portal accessed by a patient may be PHI in combination with a health condition. |
| 4 | |
| 5 | The skill is structured around the four HIPAA rules with emphasis on the Security Rule's three safeguard categories (Administrative / Physical / Technical) — that's where engineering work happens. Privacy Rule, Breach Notification Rule, and HITECH layer on top. |
| 6 | |
| 7 | Final compliance determinations stay with counsel and your privacy officer; this skill is the technical engineering layer. |
| 8 | |
| 9 | Cross-references: `privacy-engineering` for the GDPR / CCPA-shaped privacy work that often overlaps; `iam-audit` for access control and authentication; `crypto-audit` for encryption-at-rest and in-transit detail; `secrets-audit` for key management; `siem-detection` for audit-log engineering; `incident-triage` and `security-comms` for breach response. |
| 10 | |
| 11 | ## Scope — who is covered and what is PHI |
| 12 | |
| 13 | ### Who must comply |
| 14 | |
| 15 | - **Covered entity (CE)** — health plans, healthcare clearinghouses, healthcare providers who transmit health info electronically in connection with HIPAA-defined transactions |
| 16 | - **Business associate (BA)** — anyone who creates / receives / maintains / transmits PHI on behalf of a covered entity (cloud hosts holding PHI, SaaS analytics, EHR vendors, billing services, even some attorneys and consultants) |
| 17 | - **Subcontractor of a BA** — also a BA. The chain extends; every link needs a BAA with the link above |
| 18 | |
| 19 | If a system handles PHI for a CE without a BAA, that's a violation regardless of how secure the handling is. |
| 20 | |
| 21 | ### What is PHI / ePHI |
| 22 | |
| 23 | PHI = individually identifiable health information held or transmitted by a CE or BA. ePHI = the electronic form. |
| 24 | |
| 25 | The 18 HIPAA identifiers (Safe Harbor de-identification list — if all are stripped, data is no longer PHI): |
| 26 | |
| 27 | 1. Names |
| 28 | 2. Geographic subdivisions smaller than state (street, city, county, ZIP — full ZIP if population < 20,000; first 3 digits OK in most cases) |
| 29 | 3. Dates more specific than year (DOB, admission, discharge, death) — for individuals over 89, even the year requires aggregation |
| 30 | 4. Phone numbers |
| 31 | 5. Fax numbers |
| 32 | 6. Email addresses |
| 33 | 7. Social Security numbers |
| 34 | 8. Medical record numbers |
| 35 | 9. Health plan beneficiary numbers |
| 36 | 10. Account numbers |
| 37 | 11. Certificate / license numbers |
| 38 | 12. Vehicle identifiers and serial numbers (including license plates) |
| 39 | 13. Device identifiers and serial numbers |
| 40 | 14. URLs |
| 41 | 15. IP addresses |
| 42 | 16. Biometric identifiers (finger, voice) |
| 43 | 17. Full-face photographs and comparable images |
| 44 | 18. Any other unique identifying number, characteristic, or code |
| 45 | |
| 46 | **Important:** removing the 18 identifiers via Safe Harbor is one of two de-identification methods. The other is Expert Determination (statistical analysis confirming low re-identification risk). De-identified data is not PHI; **pseudonymized data is still PHI** (because the key linking the surrogate back to the individual is still held somewhere). |
| 47 | |
| 48 | ### Scope reduction patterns |
| 49 | |
| 50 | The most common scope reductions: |
| 51 | |
| 52 | - **Limit data classes collected** — if you don't need DOB, don't collect it; don't transmit it; don't store it |
| 53 | - **Pseudonymize internally** where regulators allow, but understand that internal pseudonyms are still ePHI (the linking table is held by the CE / BA) |
| 54 | - **Use BA-signed services** where possible — AWS, Google Cloud, Azure, Stripe Healthcare, certain analytics vendors sign BAAs; many SaaS tools do not |
| 55 | - **Use services that contractually commit to never receive PHI** — analytics platforms that scrub on ingest, error reporters with strict PII filtering |
| 56 | |
| 57 | ## Security Rule — the three safeguard categories |
| 58 | |
| 59 | ### Administrative safeguards (program-level) |
| 60 | |
| 61 | These are policy and program controls. Engineering teams contribute artifacts; the privacy officer owns the program. |
| 62 | |
| 63 | - **§164.308(a)(1) Security Management Process** — risk analysis (the foundati |