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

• Support of 7.1.8 requires ability to know original data and new data when modify or delete. To fully support this, will need to not delete patient documents (instead need to flag them as deleted).

(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:

• Record changes in user privileges (to fully support this, added logging for when change a user's access control group) (COMPLETED)
• Will need to not delete patient documents (instead need to flag them as deleted). (PENDING)