A composed authorization policy plus per-member tracking: every active member holds a current authorization record, every active role has a matrix row, and supervisor-required roles have one named.
Authorization is a decision made before access, not a description written after it. The difference shows up the moment someone asks who approved a given person’s access, and when.
Your authorization policy is the largest in the library, twenty-five clauses, shaped heavily by what is true about your clinic. Telehealth systems, mobile and field activity, staff-owned devices, AI tooling, paper records, and shared workstations each pull in the clauses that apply.
It covers access by role class rather than per person, with the role access matrix named as the authoritative record. Clearance precedes authorization. A confidentiality agreement is signed before first access. Role changes trigger re-authorization. Elevated access is time-limited and expires. Emergency break-glass access is defined in advance. Trainees hold no credentials until cleared. Your approver, your access review cadence, and your elevation expiry are rendered from your own recorded settings.
Seven requirements, several working per member:
The third one is the one clinics fail quietly. Authorization records age out, and a member who was properly authorized two years ago is not currently authorized under this check.
The matrix check confirms a row exists for every active role. It does not evaluate what that row grants, so a matrix row giving a receptionist full clinical access satisfies this requirement. Judging whether the grant is appropriate is your work, not the system’s.
The system also does not enforce access in any real system. It tracks whether the authorization decision was made, recorded, and kept current, per person, and tells you which members are missing one.
A per-member authorization record with dates, not a claim that everyone was approved at some point. A complete role matrix. Named supervisors where the role requires one. And a list of anyone whose authorization has aged out, before the investigator finds it.
The regulation: read the rule behind this control.
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