Purpose: Monitor and govern every instance of emergency or exceptional PHI access (“break-the-glass”) across systems. Enforces justification workflows, alerts compliance reviewers, and ensures that all overrides of Minimum Necessary and consent restrictions are properly documented and reviewed.
Core Capabilities
- Event Capture: Logs all emergency access requests, including system, user, patient, role, timestamp, and justification note.
- Justification Workflow: Requires users to declare purpose (Treatment, Emergency, Legal Hold, etc.) and duration of elevated access.
- Real-Time Alerts: Notifies privacy and compliance teams immediately when break-the-glass mode is invoked.
- Automatic Revocation: Access is rolled back to normal privileges once the defined time window expires or the event is closed.
Investigation & Review
- Dedicated reviewer console for privacy/compliance staff to validate each event’s justification.
- Cross-links to Audit Event Hub for full session traceability (which records were opened, exported, or printed).
- Disposition workflow: Validated, Escalated, or Policy Violation with comments and attachments.
Compliance & Evidence
- Aligns with HIPAA §164.308(a)(3)(ii)(C) and §164.312(a)(1) for emergency access procedures.
- Maintains immutable evidence of each override, its rationale, and supervisory review outcome.
- Automated quarterly review reports for OCR audit readiness.
Analytics & Dashboards
- Visual trend reports by department, user role, and justification type.
- Time-to-closure metrics for pending reviews.
- Heat map of systems or workflows with most frequent emergency overrides.
Integration
- Hooks into EMRs, FHIR APIs, and access control systems to trigger BTG mode at runtime.
- Feeds review results to Access Review Console and Sanction & Disciplinary Log.
Value
- Privacy: Prevents misuse of emergency access and documents every exception.
- Compliance: Creates a defensible audit trail for all override events.
- Operations: Ensures emergency access is available when truly needed, but always governed and reviewed.