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HITRUST Levels and the HITRUST CSF Control Maturity Model

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The HITRUST Alliance has helped streamline cybersecurity and compliance for companies across all industries since it was founded in 2007. It offers businesses the CSF—a unified regulatory framework that combines controls from various others into a single simplified system.

The HITRUST levels gauge a company’s security maturity across all the controls it implements.

 

An In-Depth Look at the Five HITRUST Maturity Levels

HITRUST maturity levels are one critical component of the overall HITRUST Approach. When companies assess their compliance, the levels offer insights into overall cybersecurity maturity.

Per HITRUST’s guide to evaluating control maturity, there are five total maturity levels:

Each level comprises “organizational-level evaluation criteria” and “requirement statement-level evaluation criteria” for scoring security controls’ maturity—critical for HITRUST certification.

Depending on the kind of HITRUST assessment you engage in, however, some or all maturity levels may not be assessed. For example, HITRUST i1 Assessments only score Implemented, whereas HITRUST r2 Assessments score Policy, Procedure, and Implemented by default (with the option of adding Measured and Managed, if desired). Self Assessments can score as many (or as few) maturity levels as desired for the purposes of the assessment (i.e., audit readiness).

 

Level 1 “Policy” Organizational Evaluation Criteria

The first level of HITRUST maturity concerns the extent to which organizations have formalized, distributed, and maintained explicit and comprehensive policies pertinent to all HITRUST CSF controls. There are six organization-level evaluation criteria for the first HITRUST maturity level:

These criteria establish a foundation for all later levels. However, the closest relationships exist between policies and procedures (at Level 2) and the implementation of both (at Level 3).

Together, the first three maturity levels comprise the core levels scored by default in risk-based HITRUST r2 Assessments, which validate compliance for up to two years. As such, they are the most critical levels to account for during implementation and overall certification preparation.

 

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Requirement Statement-level Criteria at Maturity Level 1

At each level, “requirement statement-level criteria” condense the organizational criteria down into specific questions applicable to any given HITRUST control. At Level 1, these include: 

These questions build on each other; the second and third assume a “yes” answer to the first.

Level 2 “Procedure” Organizational Evaluation Criteria

The second level of HITRUST maturity concerns the specific procedures prescribed in company policies pertinent to all HITRUST CSF controls. Level 2 builds upon Level 1, measuring documented procedures’ scope relative to all elements of a given control’s implementation.

There are six organization-level evaluation criteria for the second HITRUST maturity level:

The language across Level 2 mirrors Level 1; the former governs the prescriptive, specific elements broken down across and within the general policies governed by Level 1.

 

Requirement Statement-level Criteria at Maturity Level 2

At Level 2, the questions about the language used in individual procedure descriptions include:

HITRUST Levels 1 and 2 are similar at the requirement statement level, just like the organizational level. Companies may consider the two Levels’ criteria as complementary.

 

Level 3 “Implemented” Organizational Evaluation Criteria

The third level of HITRUST maturity concerns the actual implementation of all procedures. Level 3 focuses on the accuracy and fidelity respective to security policies and their general efficacy.

There are just three organization-level evaluation criteria for the third HITRUST maturity level:

Implementations must build on sound policies and procedures to guarantee their pragmatic efficacy. Implemented is the last maturity level scored by default in r2 Assessments; it is also the only level scored in the 1-year, i1 Assessments. Organizations seeking moderate cybersecurity assurance for moderate effort and preparedness should prioritize this level as most critical.

 

Requirement Statement-level Criteria at Maturity Level 3

The criteria above condense further into just two specific questions at HITRUST Level 3:

Despite the dearth of criteria here, Level 3 is still challenging. The first of these questions is the most comprehensive within the entire framework aside from Level 5’s omnibus question.

 

Level 4 “Measured” Organizational Evaluation Criteria

The fourth level of HITRUST maturity concerns assessment metrics for all controls’ efficacy in practice over time. This is similar to other frameworks’ criteria, such as AICPA’s internal control protocols. HITRUST’s criteria are distinct in prescribing long-term, continuous monitoring, both respective and adaptive to evolving risk environments, per 10 organizational evaluation criteria:

Level 4 comprises the most criteria of any level. Requirements for ongoing monitoring and adaptation can prove especially challenging for companies accustomed to fewer audits.

However, this level is not scored by default in HITRUST r2 Assessments—neither is Level 5. An organization may still choose to score them, though, if heightened security assurance is desired for other regulatory needs, to satisfy stakeholder demands, or create a competitive advantage.

 

Requirement Statement-level Criteria at Maturity Level 4

The organizational criteria for Level 4 become five questions on specific controls’ measurement:

Curiously, Level 4’s abundance of organizational criteria does not translate into a similarly burdensome set of requirement statement-level questions.

 

Level 5 “Managed” Organizational Evaluation Criteria

The fifth and final level of HITRUST maturity concerns ongoing management in response to risks and irregularities identified through monitoring. It gauges an institution’s ability to analyze root causes behind risks, mitigate them, and prevent similar future incidents. In total, this includes nine organization-level evaluation criteria:

These criteria prioritize security needs alongside business ones because seemingly small security incidents can cause irreparable damage to the most successful businesses.

Like with Level 4, Managed is only necessary if organizations seek security assurance beyond what a baseline HITRUST r2 Assessment provides (e.g., for compliance or competitiveness).

Requirement Statement-level Criteria at Maturity Level 5

Finally, the questions applied to individual requirement statements for controls include:

Answering these questions affirmatively about all applicable controls can lead to HITRUST certification at full maturity. But first, companies need to implement the HITRUST CSF.

 

HITRUST CSF Controls Subject to the HITRUST Levels’ Criteria

The HITRUST Levels’ criteria are applied to Controls from the CSF framework. This occurs during assessment, which grades out specific requirements within Controls with tiered scores corresponding to the percentage of affirmative answers to the questions detailed above.

In particular, MyCSF assessment measures an organization’s implementation of Control Specifications, also titled “References” (156 total). These are distributed across the 14 Control Categories and their 49 Objectives. The Control Categories break down as follows: 

Regardless of what kind of assessment you engage in (i1, r2, etc.), how many controls you need to implement, and to what level, it is critical to understand the entire scope of the CSF.

 

RSI Security: Certification Advisory at All HITRUST Levels

Companies seeking HITRUST certification because of an industry requirement or client request may find implementation challenging without professional help. RSI Security offers dedicated HITRUST advisory services ranging from guided implementation to assessment at all HITRUST levels. Contact RSI Security today to understand and improve your cybersecurity maturity!

 

 


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