Why this matters
HIPAA allows emergency access but mandates accountability and post-access review.
Emergency access to ePHI must go through a dedicated break_glass path that requires reason, approver, limited time window, and automatic post-incident review. The PR must include changes to the audit log schema and runbook.
HIPAA allows emergency access but mandates accountability and post-access review.
Side-by-side examples engineers can pattern-match during review.
PR description:
"Adds /emergency-access endpoint"PR description:
- Add POST /break_glass with required {reason, approverId, expiresAt}
- Audit: audit_log.action=BREAK_GLASS, fields {reason, approverId}
- Runbook: incident-review.md updated
- Alerts: pager rule for BREAK_GLASS events- Add /emergency-access
- no audit updates- Add /break_glass with reason+approver
- Update audit schema and runbookFrom the same buckets as this rule.
Before persisting ePHI, encrypt using a data key protected by a Key Management Service (KMS). Use authenticated encryption (AES-256-GCM or equivalent), rotate keys, and store the key id and algorithm with the record.