# HIPAA (45 CFR Part 164) 164.524(a)(4) — Review of denial of access - Source: https://support.icompaas.com/compliance/hipaa/164-524-a-4-review-of-denial-of-access - Section: [Compliance](https://support.icompaas.com/compliance) › [HIPAA Security, Privacy & Breach-Notification Rules](https://support.icompaas.com/compliance/hipaa) › Privacy Rule — §164.524 - Last updated: 2026-06-05 - Publisher: iCompaas, Inc. (https://www.icompaas.com) **HIPAA (45 CFR Part 164)**·§ `164.524(a)(4)`·medium·Component: **Privacy Rule** ## What this control requires > Standard: Access to protected health information. (4) Review of a denial of access. If access is denied on a ground permitted under paragraph (a)(3) of this section, the individual has the right to have the denial reviewed by a licensed health care professional who is designated by the covered entity to act as a reviewing official and who did not participate in the original decision to deny. The covered entity must provide or deny access in accordance with the determination of the reviewing official under paragraph (d)(4) of this section. 164.524(d) Implementation specifications: Denial of access. If the covered entity denies access, in whole or in part, to protected health information, the covered entity must comply with the following requirements: (4) Review of denial requested. If the individual has requested a review of a denial under paragraph (a)(4) of this section, the covered entity must designate a licensed health care professional, who was not directly involved in the denial, to review the decision to deny access. The covered entity must promptly refer a request for review to such designated reviewing official. The designated reviewing official must determine, within a reasonable period of time, whether or not to deny the access requested based on the standards in paragraph (a)(3) of this section. The covered entity must promptly provide written notice to the individual of the determination of the designated reviewing official and take other action as required by this section to carry out the designated reviewing official's determination. > > — HIPAA (45 CFR Part 164), § 164.524(a)(4) ### In plain English Standard: Access to protected health information. In practice, this means you can prove you information requirements-level controls on a defined cadence. ## Why it matters HIPAA non-compliance is a strict-liability matter: OCR civil monetary penalties are assessed per-record per-violation (up to USD 1.9 million per identical-violation calendar year as of 2024), and willful neglect can trigger criminal referral. ## What an auditor looks for HHS OCR investigators and SOC-2+HIPAA auditors look for the specific 45 CFR § citation, whether the safeguard is required vs addressable (and if addressable, the documented decision), the implementation specification, the workforce member responsible, and the records that show it runs. Within **Privacy Rule**, the assessor will trace your implementation back to the catalogue reference (§ 164.524(a)(4)) and look for objective evidence on the latest two assessment cycles. ## How to implement #### Policy Management **Docs.** Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA. ### Operational checklist - **Information.** Document the trigger, the owner and the cadence. - **Other.** Document the trigger, the owner and the cadence. - **Requirements.** Document the trigger, the owner and the cadence. - **Policy.** Document the trigger, the owner and the cadence. - **Notice.** Document the trigger, the owner and the cadence. - **Scope:** requirements, management, notice, determination, policy, accordance, section, d. ## Evidence to collect - **Policy Document.** A signed and version-controlled policy / standard / procedure document. Signed policy or standard documents the safeguard. Focus: Review of denial of access. ## Common pitfalls - Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced. ## How it maps to other frameworks Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit. - [**NIST SP 800-53 Rev. 5 PL-2(1)** — Concept Of Operations](https://support.icompaas.com/compliance/nist-sp-800-53-rev-5/pl-2-1-concept-of-operations) - [**ISO/IEC 27001:2022 A.8.26** — Application security requirements](https://support.icompaas.com/compliance/iso-27001-2022/a-8-26-application-security-requirements) - [**BSI C5:2020 SP-01** — Documentation, communication and provision of policies and instructions](https://support.icompaas.com/compliance/bsi-c5-2020/sp-01-documentation-communication-and-provision-of-policies-and-instructions) ## Related controls in HIPAA (45 CFR Part 164) - [**§ 164.524(d)(4)** — Review of denial requested](https://support.icompaas.com/compliance/hipaa/164-524-d-4-review-of-denial-requested) - [**§ 164.520(e)** — Documentation](https://support.icompaas.com/compliance/hipaa/164-520-e-documentation) - [**§ 164.530(b)** — Training](https://support.icompaas.com/compliance/hipaa/164-530-b-training) - [**§ 164.530(i)** — Policies and Procedures](https://support.icompaas.com/compliance/hipaa/164-530-i-policies-and-procedures) - [**§ 164.524(a)(3)** — Reviewable grounds for denial](https://support.icompaas.com/compliance/hipaa/164-524-a-3-reviewable-grounds-for-denial) - [**§ 164.530(e)(1)** — Sanctions](https://support.icompaas.com/compliance/hipaa/164-530-e-1-sanctions) ## References - [U.S. HHS Office for Civil Rights — HIPAA (45 CFR Part 164)](https://www.hhs.gov/hipaa/for-professionals/index.html) - Catalogue identifier: `§ 164.524(a)(4)` Topics: governance riskpolicy management ## Related compliance guidance - [HIPAA compliance for SaaS: a practical implementation guide](https://support.icompaas.com/compliance/hipaa): Start with the full HIPAA implementation guide — scope, roadmap, evidence and how the assessment runs. - [SOC 2 compliance: a practical implementation guide for cloud-native SaaS teams](https://support.icompaas.com/compliance/soc-2-trust-services-criteria): Most covered-entity customers accept a SOC 2 Type II report as the independent evidence that your HIPAA controls operate, since no HIPAA attestation exists. - [NIST SP 800-53 Rev. 5: a practical implementation guide for cloud teams](https://support.icompaas.com/compliance/nist-sp-800-53-rev-5): NIST publishes mappings of the Security Rule standards and implementation specifications to SP 800-53 Rev. 5 controls alongside SP 800-66 Rev. 2, so an 800-53 control set doubles as a HIPAA crosswalk.