An inventory of loggable systems covering your PHI vendors, reviews tracked against each entry's cadence, and anomalies that cannot sit open indefinitely.
Audit controls generate the logs. This is the standard that requires someone to read them, and it is the half almost nobody does, because nothing announces the failure.
Your activity review policy covers what gets reviewed, audit logs and access reports and system activity, how often, rendered from your own recorded cadence, who performs the review, what a review looks for, how it relates to your audit controls policy, and documentation with retention.
Ten requirements, several reconciling across records:
The per-entry cadence is what makes this real. A system set to weekly review goes stale after seven days, not ninety, so a single blanket “we review quarterly” cannot cover a system that needs closer watching.
The system tracks that review records exist, on schedule, per inventory entry, and that anomalies and escalations resolved. It does not read your logs, and it cannot tell you whether the reviewer actually looked carefully or caught what was there. A recorded review is a person saying they looked.
What it does prevent is the review quietly stopping. Cadence windows expire, anomalies age, scheduled events come due, and each of those becomes visible rather than forgotten.
An inventory of the systems that hold PHI and produce logs. A dated review history per system, on its own cadence. Quarterly summaries. An anomaly trail showing what was found and how it resolved. Evidence that examining actually happens, which is the half of this obligation with nothing to show in most clinics.
The regulation: read the rule behind this control.
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