Medical billing companies, healthcare providers, and business associates must track who accesses protected health information (PHI)—but many fail to do so correctly.
Without proper logging, organizations can’t:
Detect unauthorized access to PHI
Prove compliance with HIPAA audits
Investigate security incidents or breaches
The result? Massive HIPAA fines, data leaks, and loss of patient trust. Let’s break down HIPAA’s logging requirements, common compliance failures, and how to fix them.
The HIPAA Security Rule mandates that covered entities and business associates:
"Implement hardware, software, and/or procedural mechanisms that record and examine activity in information systems that contain or use electronic protected health information (ePHI)." (45 CFR § 164.312(b))
Prevents insider threats – Employees snooping on records can be detected early
Identifies unauthorized access – Detect breaches before they escalate
Enables forensic investigations – Logs provide proof of what happened and when
Ensures accountability – Organizations must show who accessed what and why
Yet many healthcare apps and billing systems fail at proper logging, exposing organizations to serious HIPAA violations.
Many organizations think HIPAA compliance stops at encryption and access controls—but without logging, you can’t prove compliance. Here’s where companies often fail:
Some medical billing platforms don’t track user access at all
No way to see who accessed patient records and when
No alerts for suspicious activity
Risk: If PHI is breached, there’s no way to trace the source or prove compliance.
Many systems only log login attempts, but HIPAA requires more than that:
Who accessed PHI (specific user ID)
Which records were viewed/modified
What action was taken (viewed, edited, exported)
Timestamp of access
Risk: Without these details, an OCR audit will likely determine non-compliance.
No automated alerts when PHI is accessed outside of normal hours
No flagging of unusual bulk data downloads or edits
No way to quickly detect insider threats
Risk: Data breaches can go undetected for months, leading to larger fines and reputational damage.
Some systems allow administrators to edit or erase logs, making them unreliable for audits.
Risk: HIPAA requires tamper-proof logging. If logs can be modified, they won’t hold up in an investigation.
HIPAA requires logs to be retained for at least six years, but some companies:
Auto-delete logs after a few months
Store logs in insecure locations
Lack a backup logging system
Risk: If OCR requests logs from two years ago and they’re gone, expect major fines.
Cignet Health failed to provide patients access to their medical records. When investigated, they had no audit logs to prove access requests were handled properly.
Key failure: No logging = No compliance proof. OCR issued one of the largest HIPAA fines at the time.
Want to avoid fines and properly track PHI access? Follow these best practices:
Ensure your EHR, billing system, or third-party application:
Records user access to PHI (who, what, when, where)
Tracks edits, deletions, and exports of PHI
Generates real-time alerts for unusual access
Prevents log tampering
HIPAA requires logs to be kept for six years. Use cloud storage or secure servers to prevent data loss.
Best practice: Review audit logs weekly and investigate unusual activity.
Pro Tip: Use AI-driven monitoring tools to detect insider threats and unauthorized access.
Restrict PHI access based on job role and necessity:
Receptionists shouldn’t access patient treatment records
Billing staff shouldn’t see full medical histories
IT teams shouldn’t access PHI unless required
Logging + RBAC = Stronger compliance & security.
Regularly generate reports to:
Show compliance to OCR auditors
Identify potential security gaps
Track how PHI is being used and by whom
Yes! HIPAA requires audit logs that track access to PHI. (45 CFR § 164.312(b))
A proper log should capture:
User ID (who accessed PHI)
Date & time of access
Which records were viewed or modified
What action was taken (viewed, edited, exported, printed)
At least six years (per HIPAA regulations).
OCR audits can result in major fines
Breach investigations will be harder to defend
You’ll have no proof of compliance
No logging = No compliance. If your healthcare or billing system doesn’t track who accessed PHI, when, and why, you’re at serious risk for HIPAA violations.
Implement a HIPAA-compliant logging system
Monitor audit logs regularly
Retain records for six years
Logging isn’t optional—it’s a fundamental part of HIPAA compliance. Make sure your system can track access, detect threats, and generate compliance reports to avoid costly fines.