Auditable events and tamper-resistance (MU3)

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.

• 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.

• TODO

• Analyze 7.1.1 through 7.1.3 and 7.1.6 through 7.1.9 of the standard specified in ASTM E2147-18
• Record changes in user privileges (to fully support this, added logging for when change a user's access control group)

(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 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).

(d)(2)(i)(C)

• End-user device encryption is always on per (d)(7), so not applicable.

(d)(2)(ii)

• All logging needs to be on by default.

(d)(2)(iii)

• Logging can only be disabled by a limited set of users.

(d)(2))(iv)

• Can not manipulate (changed, overwritten, or deleted) log.

(d)(2))(v)

• Need to detect manipulation of log.

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.

Progress:

• ASTM E2147-18 7.1.1 through 7.1.3 and 7.1.6 through 7.1.9, 7.2 and 7.4
• Any changes to a user’s privileges must be captured to meet this criterion (e.g., user account creation, user switches roles and new privileges are assigned, revoking privileges, account disabling, etc.).