HIPAA Security RuleNIST SP 800-161 Rev 1

HIPAA Security Rule covers 17.3% of NIST SP 800-161 Rev 1

33 of the 191 controls in NIST SP 800-161 Rev 1 are already satisfied by evidence you collected for HIPAA Security Rule. 158 are genuine gaps. Every claim below was judged against both control sets and then argued against; the ones that did not survive are published further down with the reason each failed.

17.3%

of the target already covered

controls evidenced

158

genuine gaps

claims rejected in review

This number is directional. It says how much of NIST SP 800-161 Rev 1 your HIPAA Security Rule evidence satisfies. The reverse pair is a different number, often very different, because a security standard has enormous depth for access control and almost none for lawful basis or data subject rights.

85 candidate mappings were examined and 0 were removed. Signed off 2026-08-19, review level machine verified. Mappings were judged by Claude Code rather than read line by line by a practitioner. Every claim shows its reasoning so you can check it. Ask and a practitioner will review this pair.

Where the gaps are

Coverage is never evenly spread. A source standard usually satisfies one part of a target almost completely and barely touches another, and which part is which is the thing worth knowing before you plan the work.

C-SCRM Family: Media Protection3 of 4 evidenced, 1 to do

C-SCRM Family: Physical and Environmental Protection5 of 9 evidenced, 4 to do

C-SCRM Family: Supply Chain Risk Management5 of 13 evidenced, 8 to do

C-SCRM Family: Access Control4 of 14 evidenced, 10 to do

C-SCRM Family: Identification and Authentication2 of 7 evidenced, 5 to do

C-SCRM Family: Risk Assessment2 of 7 evidenced, 5 to do

C-SCRM Family: Personnel Security1 of 4 evidenced, 3 to do

C-SCRM Family: Audit and Accountability2 of 9 evidenced, 7 to do

C-SCRM Family: Incident Response2 of 9 evidenced, 7 to do

C-SCRM Family: System and Communications Protection2 of 14 evidenced, 12 to do

C-SCRM Family: Planning1 of 7 evidenced, 6 to do

C-SCRM Family: System and Services Acquisition2 of 15 evidenced, 13 to do

C-SCRM Family: System and Information Integrity1 of 8 evidenced, 7 to do

C-SCRM Family: Program Management1 of 30 evidenced, 29 to do

C-SCRM Family: Awareness and Training0 of 4 evidenced, 4 to do

C-SCRM Family: Assessment, Authorization, and Monitoring0 of 6 evidenced, 6 to do

C-SCRM Family: Configuration Management0 of 14 evidenced, 14 to do

C-SCRM Family: Contingency Planning0 of 8 evidenced, 8 to do

C-SCRM Family: Maintenance0 of 8 evidenced, 8 to do

C-SCRM Family: Personally Identifiable Information Processing and Transparency0 of 1 evidenced, 1 to do

Theme level, not control level, deliberately. The per-control list of what is evidenced and what is a gap is the report itself, so publishing it here would be publishing the thing being sold.

Claims that held

A sample. Each one names the control whose evidence does the work, the control it satisfies, and why.

164.308(a)(4)(ii)(B)AC-2argued against and upheld

Account Management

Access authorization runs the request, approval and provisioning lifecycle for every account granted access.

164.314(a)(2)(i)AC-20argued against and upheld

Use of External Systems

Sets the binding terms under which an external party may process organisational information.

164.312(a)(1)AC-3argued against and upheld

Access Enforcement

Technical access control permits only authorised persons or software programs to reach protected data.

164.308(a)(4)(i)AC-6argued against and upheld

Least Privilege

Information access management requires minimum necessary, role based and least privilege access.

164.312(b)AU-12argued against and upheld

Audit Record Generation

Audit controls require mechanisms that record activity in systems holding protected data.

164.308(a)(1)(ii)(D)AU-6argued against and upheld

Audit Review, Analysis, and Reporting

Requires regular review of audit logs, access reports and incident tracking reports.

164.312(d)IA-2argued against and upheld

Identification and Authentication (Organizational Users)

Person or entity authentication verifies each individual claiming access, including external staff.

164.312(a)(2)(i)IA-2argued against and upheld

Identification and Authentication (Organizational Users)

Unique user identification forbids shared accounts so external personnel are individually attributable.

Claims that did not hold

Nothing proposed for this pair was rejected in review. That is unusual and worth knowing rather than hiding: it means the candidate set was small and every candidate held.

The full report

Everything above is a sample. The report is every evidenced control and every gap, with the reasoning and the source document behind each one, in a form you can hand to an assessor. $299, emailed immediately.

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