Compliance · HIPAA Security Rule
Does HIPAA require human code review when AI reviews the code?
HIPAA does not name code review, but 45 CFR 164.308(a)(1)(ii)(B) requires risk management measures and 164.308(a)(8) requires periodic evaluation, and assessors expect documented development controls proportional to ePHI risk. An AI reviewer alone does not document who approved a change to an ePHI-handling path. With PSCO those paths are Deep Review by default, and every change touching them carries a named Officer’s decision and an attestation record.
The mapping row
| Framework | Control | What it asks | How PSCO satisfies it |
|---|---|---|---|
| HIPAA Security Rule | 45 CFR 164.308(a)(1)(ii)(B) Risk management; 164.308(a)(8) Evaluation | No explicit code-review rule; assessors expect documented SDLC controls proportional to ePHI risk | ePHI-handling paths are Deep Review by default; evidence of review on every change touching them |
Suggested control wording
Name the approver. Name the standard.
Paste this into your control description. The first sentence is the control; the second names the reviewer and the standard they review against, which is what an auditor needs to accept an outside approver.
All changes to production code require approval from a qualified reviewer who is not the author. Reviewers are PSCO Officers, background-checked US-based engineers contracted by the company, who review each change against the company’s Security & Compliance Model before approval.
Mark ePHI-handling paths as deep in the Security & Compliance Model. The attestation for every change on those paths records the tier, so the evidence shows the deeper review was applied where the risk is.
What a HIPAA auditor samples
Build the record so it is already there.
Auditors test change management by sampling. These are the facts they look for on each sampled change, and where PSCO puts them.
- 01Documented SDLC controls and evidence they are followed for systems that touch ePHI.
- 02Evidence of review and approval for changes to ePHI-handling code.
- 03The risk analysis tying review depth to ePHI exposure, which the model’s tiering records.
Auditor Guide
Hand your auditor the design once. Then they recommend it.
Before public launch PSCO briefed audit firms that together cover most startup and mid-market SOC 2 reports on the control design, the Officer Dossier and the Evidence Pack. The Auditor Guide is their questions, answered, for your auditor to read before the first sample.
The control design, the Officer Dossier and the Evidence Pack, written for your auditor.
A short PDF that answers the questions audit firms asked when we briefed them: who the approver is, how they are qualified, what the attestation records, and how to sample it. Enter a work email and we send the guide.
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