How can a system track who accessed ePHI?

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  1. Let staff share one login
  2. Give patients user IDs
  3. Assign unique user IDs to track user identity

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References

  1. 45 CFR 164.312(a)(2)(i) www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-C/section-164.312 Checked 2026-10-10.

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