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Auditable events and tamper-resistance (MU3)

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Status

  • VERIFIED COMPLETE
  • Ready to sign self-declaration.

Notes

D2.png


Issues:
(d)(2)(i)(A)
  • The audit log must record the information specified in sections 7.1.1 through 7.1.3 and 7.1.6 through 7.1.9 of the standard specified in ASTM E2147-18 and changes to user privileges when health IT is in use. (PASS)
  • CLARIFICATION
  • Support for 7.1.3 (Duration of access) was dropped since was not felt to be in scope for certifying and testing to 2015 Edition Cures Update certification.
(d)(2)(i)(B)
  • The audit log must record the information specified in sections 7.2 and 7.4 of the standard specified in ASTM E2147-18 when the audit log status is changed. Interestingly, 7.2 and 7.4 do not exist in ASTM E2147-18, but in a prior ASTM E2147-01 version used in MU2, 7.2 was 'Date and Time of Event' and 7.4 was 'User Identification'; notably there was a clarification to fix this and need to support 7.1.1 (Date and Time of access event) and 7.1.7 (User Identification). (PASS)
(d)(2)(i)(C)
  • End-user device encryption is always on per (d)(7), so not applicable. (PASS)
(d)(2)(ii)
  • All logging needs to be on by default. (PASS)
(d)(2)(iii)
  • Logging can only be disabled by a limited set of users. (PASS)
(d)(2))(iv)
  • Can not manipulate (changed, overwritten, or deleted) log. (PASS)
(d)(2))(v)
  • Need to detect manipulation of log. (PASS)
Final:
  • To ensure accurate time, server will need to set up a Network Time Protocol server that supports version 4 Network Time Protocol (NTP) as defined by RFC 5905.