HIPAA Security Audits?

["H. Morrow Long" <morrow.long () YALE EDU>]

Have any higher ed institutions decided how/if they are going to perform
audits of departments and/or systems to assess compliance with the HIPAA
Security regulations -- and if so what the audit assessment procedure(s)
would be?  I'm also interested in who would be performing these audits,
how often they would take place and what criteria would be used to
determined who/what/it would be audited (primary/secondary ePHI data,
etc.).   Have you received any advice as to what is considered to be a
reasonable policy/procedure from your legal or audit department (e.g.
is 'system activity review' of system logs for ePHI systems by the
school
or department considered sufficient or is -- in addition -- a random
spot
check or regular audit of both physical and IT security of such systems
to be conducted?  Respond in public or private -- a summary of the
responses will be posted.

- H. Morrow Long, CISSP, CISM, CEH
  University Information Security Officer
  Director -- Information Security Office
  Yale University, ITS

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