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HIPAA Security Rule, Implementation Guidance NIST SP 800-66 Revision 2 (NIST_SP_800_66R2) ​

At a glance ​

PropertyValue
Framework ID (for regimes_active)NIST_SP_800_66R2
Authority / publisherU.S. Department of Health and Human Services (45 CFR Part 164 Subpart C, Security Rule); implementation guidance by NIST (SP 800-66 Revision 2, February 2024)
VersionNIST SP 800-66r2 / 2024-02
StatusNot declared in the catalogue metadata
SWAO catalogue version0.1.0
Total controls49
Scoring modebinary (declared). The catalogue also maps the native HIPAA rating to SWAO outcomes, see below.
Assessment scope (framework-meta)app, aud
Signal prefixHIPAA
Licence and redistributionNIST SP 800-66r2 is a U.S. Government work not subject to copyright in the United States (17 USC 105); the Security Rule is federal regulation. Titles are verbatim, descriptions paraphrased.
Last reviewed2026-05-23

What it is ​

The HIPAA Security Rule (45 CFR Part 164 Subpart C) is U.S. federal regulation under the Health Insurance Portability and Accountability Act. It requires covered entities (health plans, healthcare clearinghouses and most healthcare providers) and their business associates to protect electronic protected health information (ePHI) with administrative, physical and technical safeguards. NIST SP 800-66 Revision 2 (February 2024) is NIST's resource guide for implementing the rule; it is guidance, not regulation.

The rule is organised into sections, standards and implementation specifications. Specifications are either Required (R) or Addressable (A): an addressable specification may be met by an equivalent alternative measure if the entity documents why. SWAO models each implementation specification as one control and groups the controls by the five sections 164.308, 164.310, 164.312, 164.314 and 164.316. This framework supersedes the earlier three-control HIPAA stub (replaces: HIPAA).

Who should use it in SWAO and when ​

Use NIST_SP_800_66R2 for any workload that stores, processes or transmits ePHI for the U.S. market: electronic health record systems, health data analytics, telehealth, claims processing and the cloud platforms that host them. It applies to covered entities and to business associates such as SaaS and hosting providers. It pairs naturally with SOC_2 for U.S. B2B buyers and with GDPR when the same health platform also serves the EU.

The framework declares a sovereignty requirement (require_certifications: [HIPAA]), which the landing zone assessment can use when it compares target platforms.

What SWAO checks ​

Controls are evaluated by the compliance pass (Pass 11, COMP). For every framework listed in assessment.regimes_active, the pass sends each control's ID, title, description and default severity, together with all signals produced earlier in the run, to the configured LLM in batches of 20 controls. The LLM returns one outcome per control with a short rationale:

OutcomeMeaning
SATISFIEDSignals positively confirm that the control is met.
PARTIALSome elements are present, but gaps remain.
GAPSignals show that the control is not met.
UNKNOWNNo signal addresses the control either way.
N_AThe control does not apply to this workload (with justification).

Signal references cited by the LLM are checked against the real signal set of the run, and evidence file paths are taken from the cited signals rather than from the LLM. Without a configured LLM provider every control is recorded as UNKNOWN and the framework status is pending-llm. A roll-up signal COMP-NN summarises the outcome counts per framework.

Each control in the catalogue also declares an evidence_basis: the signal family or document it is meant to be judged on. The evaluator does not filter on this field. It tells reviewers which evidence matters and is shown in the HTML publication as the scope of the automated check. Documents such as policies, runbooks and architecture descriptions reach the run through the ingest and context passes.

The catalogue maps the native HIPAA posture onto SWAO outcomes (rating_scale in framework-meta.yaml):

HIPAA postureSWAO outcomeSeverity floor
Fully implemented (R) / implemented or alternative measure (A)SATISFIED
Partially implementedPARTIAL
Not implemented, no alternative measure documented (A)GAPhigh
Not implemented (R)GAPcritical
Not applicableN_A

Technical safeguards are where code and configuration evidence helps most: 7 of the 9 technical controls declare a signal family and one (HIPAA-TEC-03) a local regular expression. Administrative, physical and documentation controls rely on documents. Ten controls declare a manual questionnaire, for example HIPAA-ADM-07 Workforce Clearance Procedure, and the framework folder ships eight evidence templates under evidence/ (four Markdown templates and four questionnaires). 16 controls declare automated evidence:

ControlTitleDeclared evidence basis
HIPAA-ADM-04Information System Activity Review (Required), 164.308(a)(1)(ii)(D)OBS
HIPAA-ADM-10Access Authorisation (Addressable), 164.308(a)(4)(ii)(B)IAM
HIPAA-ADM-11Access Establishment and Modification (Addressable), 164.308(a)(4)(ii)(C)IAM
HIPAA-ADM-14Log-in Monitoring (Addressable), 164.308(a)(5)(ii)(C)OBS
HIPAA-ADM-15Password Management (Addressable), 164.308(a)(5)(ii)(D)IAM
HIPAA-ADM-17Data Backup Plan (Required), 164.308(a)(7)(ii)(A)DR
HIPAA-ADM-18Disaster Recovery Plan (Required), 164.308(a)(7)(ii)(B)DR
HIPAA-PHY-10Data Backup and Storage (Addressable), 164.310(d)(2)(iv)DR
HIPAA-TEC-01Unique User Identification (Required), 164.312(a)(2)(i)IAM
HIPAA-TEC-03Automatic Logoff (Addressable), 164.312(a)(2)(iii)local_signal_regex
HIPAA-TEC-04Encryption and Decryption at Rest (Addressable), 164.312(a)(2)(iv)CRYPTO (Pass 08)
HIPAA-TEC-05Audit Controls (Required), 164.312(b)OBS
HIPAA-TEC-06Integrity Mechanism for ePHI (Addressable), 164.312(c)(2)CRYPTO (Pass 08)
HIPAA-TEC-07Person or Entity Authentication (Required), 164.312(d)IAM
HIPAA-TEC-08Integrity Controls in Transit (Addressable), 164.312(e)(2)(i)CRYPTO (Pass 08)
HIPAA-TEC-09Encryption in Transit (Addressable), 164.312(e)(2)(ii)CRYPTO (Pass 08)

Note: this catalogue declares the signal families DR, IAM, OBS. No pass in the current release emits signals with these prefixes, so the affected controls are in practice judged on related signals (for example Terraform, egress or cryptography findings) and on context documents.

Control structure ​

Each control is tagged on the axes section, family, requirement and applies-to. By requirement tag, 22 controls are Required, 22 Addressable and 5 are standard-level controls without a separate implementation specification (HIPAA-ADM-05, HIPAA-ADM-22, HIPAA-PHY-05, HIPAA-PHY-06, HIPAA-PND-01).

Domain / pillarControlsDeclared automated evidenceExample controls
Administrative Safeguards237HIPAA-ADM-01 Risk Analysis (Required), 164.308(a)(1)(ii)(A); HIPAA-ADM-02 Risk Management (Required), 164.308(a)(1)(ii)(B)
Physical Safeguards101HIPAA-PHY-01 Contingency Operations (Addressable), 164.310(a)(2)(i); HIPAA-PHY-02 Facility Security Plan (Addressable), 164.310(a)(2)(ii)
Technical Safeguards98HIPAA-TEC-01 Unique User Identification (Required), 164.312(a)(2)(i); HIPAA-TEC-02 Emergency Access Procedure (Required), 164.312(a)(2)(ii)
Organisational Requirements30HIPAA-ORG-01 Business Associate Contracts (Required), 164.314(a)(2)(i); HIPAA-ORG-02 Other Arrangements (Required), 164.314(a)(2)(ii)
Policies and Procedures and Documentation40HIPAA-PND-01 Policies and Procedures: 164.316(a); HIPAA-PND-02 Documentation Time Limit (Required), 164.316(b)(2)(i)
Total4916

Cross-mapping to other frameworks ​

Per-control mappings in controls.yaml (maps_to), counted by target framework:

Target frameworkControls with at least one maps_to reference
ISO_2700143
SOC_229

Declared cross-mapping hints in framework-meta.yaml (framework level, not per control): ISO_27001, SOC_2, COBIT_5, GDPR, DORA, NIST_CSF_2, NIST_800_53R5, HITRUST_CSF, PCI_DSS, ISO_27799.

Demo variant ​

Two demo-sized subsets exist. They contain the same 12 controls with the same IDs (HIPAA_DEMO.ADM_01 and similar): six administrative safeguards, five technical safeguards and one organisational requirement, selected for cross-regime coverage with GDPR_DEMO, AI_10_PILLARS_DEMO and BSI_GRUNDSCHUTZ_2023_DEMO.

Framework IDFolderControlsNotes
NIST_SP_800_66R2_DEMOnist-sp-800-66r2-demo12Seeded into every new workspace by swao init and shown by swao framework list.
NIST_HIPAA_DEMOnist-hipaa-demo12Same content under a different ID; its framework-meta.yaml sets listed: false, so swao framework list does not show it, and it is not seeded.

Enable only one of the two in an application, because they evaluate the same controls. Use the full NIST_SP_800_66R2 for client deliverables.

How to enable ​

  1. Discovery. Copy the folder nist-sp-800-66r2-hipaa into the workspace at wsp/inputs/catalogs/community/nist-sp-800-66r2-hipaa/ (see the next section). Any framework folder there is discovered automatically; no registration is needed. The TUI framework selection (Run Assessment, then the application's framework step) offers it, and the compliance pass resolves catalogues from this workspace folder. In the TUI, the framework picker for application assessments lists installed frameworks whose assessment_type_scope includes app. This framework declares app and aud, so it appears there; the landing zone assessment picker lists all installed frameworks.

  2. Selection. The chosen frameworks are stored per application in apps/<app-id>/.swao.yml as assessment.regimes_active, and the compliance pass evaluates exactly that list. The TUI writes the entry for you; on the command line use swao regime-select --app <app-id> --regimes NIST_SP_800_66R2. As a manual alternative, edit the application's .swao.yml:

    yaml
    assessment:
      regimes_active: [NIST_SP_800_66R2]

    Several frameworks can be combined in one list. To assess several applications against the same framework, add the ID to each of them.

  3. Workspace level. A regimes_active list in the workspace .swao.yml applies to every application that has no list of its own. A list in the app always takes precedence.

  4. Check. Run swao health-check: it reports IDs in regimes_active that have no installed catalogue.

Get or customise this framework ​

The framework source (framework-meta.yaml, controls.yaml and any supporting files) is public. You can view it on GitHub and copy and paste it:

To customise the framework for one engagement, copy the folder nist-sp-800-66r2-hipaa into your workspace at wsp/inputs/catalogs/community/nist-sp-800-66r2-hipaa/ and edit the copy there, for example to adjust severities or to add engagement-specific controls. This workspace folder is what SWAO reads; the original bundled with SWAO stays unchanged. Place the copy directly under community/, because folders whose name starts with a dot are skipped. Keep regime_meta.id unique: if two workspace folders declare the same ID, only one of them is loaded. swao framework info NIST_SP_800_66R2 prints the bundled metadata.

Limitations and notes ​

  • SWAO produces an evidence-based pre-assessment. It is not a certification, an audit opinion or legal advice. Review every SATISFIED and GAP outcome before relying on it, and involve qualified auditors or counsel for formal compliance statements.
  • Outcomes depend on the evidence available to the run (code, configuration, infrastructure-as-code, ingested documents) and on LLM judgement. Where no signal addresses a control, the LLM is instructed to return UNKNOWN, not GAP.
  • Organisational, physical and contractual controls cannot be proven from code. They need documents supplied by the client.
  • HIPAA-TEC-03 Automatic Logoff declares a local regular expression over source and configuration files (session or idle timeout settings). The compliance pass does not run this expression itself; the control is judged like all others on the run's signals.
  • Business associate agreements, workforce sanctions and facility controls need documents from the client.
  • A HIPAA compliance determination is made by the covered entity and, in enforcement, by the HHS Office for Civil Rights; SWAO results are preparatory.