Practitioner-depth guides on FISMA, FedRAMP, CMMC, DCAA audit readiness, and AI governance for federal systems. Written by a CPA, CISSP, CISA with Big 4 audit experience.
When the AICPA released the Trust Service Criteria in 2017, it replaced the older Trust Service Principles framework with a structure aligned to COSO Internal Control. The change was more than nomenclature. The new framework...
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The compliance consultant delivered the recommendation on a Thursday: "Start with Type 1 to get something on paper quickly." The VP of Sales forwarded the procurement requirement the same morning: "Vendor must provide SOC 2...
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The "Right to Audit" clause in your Business Associate Agreement is a liability, not a protection. Compliance teams draft aggressive audit provisions granting the covered entity permission to inspect vendor firewalls, review security configurations, and...
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The compliance officer documented the exception in 2021. Line item: Encryption at rest. Classification: "Addressable, Not Implemented." Justification: legacy EHR servers do not support AES-256, and hardware replacement exceeds the current budget cycle. The risk...
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Three thousand nine hundred patients. One unencrypted laptop. One parked car. The theft triggered a breach notification to every patient, a media disclosure to local news outlets, and an OCR investigation that ended in a...
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Organization A downloads the HHS Security Risk Assessment Tool, changes the organization name, and answers 40 yes/no questions in two hours. The spreadsheet goes into a shared drive with "FINAL" in the filename. When an...
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How many systems in your organization touch Protected Health Information? Not the ones your IT department provisioned. All of them. The 23 AWS S3 buckets your cloud billing statement reveals. The Salesforce instance storing patient...
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An AI risk assessment identifies, analyzes, and treats risks specific to AI systems: bias, hallucination, data provenance, and decision accountability. The NIST AI RMF 1.0 structures the process into four functions: Govern, Map, Measure, and...
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NIST released CSF 2.0 in February 2024, the first major framework revision in a decade. The update added a sixth function (Govern), expanded applicability beyond critical infrastructure to all organizations, and introduced implementation tiers replacing...
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Two million and thirty thousand dollars. The cost difference between organizations that test their incident response plans and those that discover their plans do not work during an actual breach. IBM's 2024 Cost of a...
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Organization A resolved 47 security incidents last quarter. The incident log shows detailed timelines, containment actions, root cause analysis, and corrective action status for each one. The SOC 2 auditor reviewed the documentation, confirmed CC7.3...
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Every HIPAA risk assessment I review commits the same fundamental error. The document is titled "Risk Assessment." The content is a checklist. MFA: yes. Encryption: yes. Backup: yes. A series of binary answers telling OCR...
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