Who Can Log In? A Quarterly Healthcare Vendor Access Review
Healthcare organizations depend on outside companies for EHR support, billing, imaging, laboratory interfaces, medical equipment, networking, Microsoft 365, copiers, telecommunications, and other essential services.
Many of these vendors require some form of system access.
The problem is not that vendors have access. The problem is access that is unknown, excessive, shared, permanent, or no longer connected to a valid business need.
How should a healthcare organization review vendor access?
Maintain one inventory of every vendor with physical, remote, administrative, cloud, application, or patient-information access.
At least quarterly, confirm:
- The vendor relationship is still active.
- A responsible internal owner is assigned.
- Each account has a valid user and purpose.
- Access is limited to what the vendor needs.
- Strong authentication is used where supported.
- Remote and unattended access is controlled.
- Relevant activity can be reviewed.
- Incident and escalation contacts are current.
- Former technicians and expired accounts are removed.
- The organization knows how access will be ended.
The review should produce a short action register with an owner and deadline for every unresolved item.
What counts as vendor access?
Vendor access is broader than a technician remotely controlling a workstation.
It may include:
- EHR or practice-management support accounts
- Microsoft 365 guest users
- Entra ID enterprise applications
- Remote-support agents
- VPN accounts
- Network and firewall administration
- Cloud-hosting portals
- Billing and clearinghouse systems
- Imaging, laboratory, and pharmacy interfaces
- Medical-device support connections
- Copier and scanner support
- Website and domain administration
- Telephone and messaging systems
- Backup and recovery platforms
- Physical keys, badges, or equipment-room access
- Shared credentials provided by an employee
- Application programming interfaces and authentication tokens
ome access paths are visible in a central directory. Others exist only inside a vendor application or on an individual device.
That is why a vendor list and a user-account list are not the same thing. A complete review must connect the vendor, its people, its technical access, and the business reason for that access.
Why review vendor access quarterly?
Vendor relationships change.
Technicians leave. Contracts expire. Applications are replaced. Support agents remain installed. Temporary accounts become permanent. A vendor may introduce a subcontractor without the organization’s operational contacts knowing.
HHS includes vendor and supplier cybersecurity requirements among its voluntary Healthcare and Public Health Cybersecurity Performance Goals. The goal is to identify, assess, and mitigate risks associated with third-party products and services.
Cybersecurity Performance Goals
NIST Cybersecurity Framework 2.0 also calls for organizations to know their suppliers, prioritize them by criticality, define responsibilities, integrate requirements into agreements, monitor risk throughout the relationship, and plan for the relationship’s conclusion. nist.gov
A quarterly review is a practical operating rhythm. It does not replace risk analysis, legal review, contract management, or immediate action when access is no longer appropriate.
Prepare for the review
Gather the following before the meeting:
- Current vendor list
- Application and system inventory
- Microsoft 365 and Entra ID accounts
- Active Directory accounts
- Remote-support software inventory
- VPN and firewall accounts
- EHR and practice-management users
- Administrative and privileged accounts
- Recent invoices and contracts
- Business associate agreements, where applicable
- Current incident and escalation contacts
- Prior vendor-review action items
Include representatives from operations, IT, practice leadership, and relevant clinical or compliance roles.
For a small practice, this may be two or three people. The important point is that technical access and business ownership are reviewed together.
Quarterly healthcare vendor-access checklist
1. Identify every vendor with access
Start with the question:
Which outside organizations can enter our facilities, connect to our systems, administer an application, or receive organizational data?
Check:
- Installed remote-support agents
- Browser-based vendor portals
- VPN and remote-desktop accounts
- Microsoft 365 guest users
- Entra ID enterprise applications
- Local computer accounts
- Firewall rules
- Shared passwords
- Physical badges and keys
- Automated integrations
- Service and API accounts
Do not rely only on the accounting vendor list. A vendor may have technical access without submitting a regular invoice.
2. Assign an internal owner
Every vendor relationship should have a named internal owner.
The owner should understand:
- Why the vendor is used
- Which service it provides
- Which systems it needs
- Who approves changes
- Who receives security notifications
- Who decides when access ends
“IT owns it” is not always sufficient. IT may administer access, but a clinical or business leader should confirm whether the service remains necessary.
3. Document the access purpose
For each vendor, record:
- Vendor name
- Service provided
- Internal owner
- Systems accessed
- Type of access
- Named vendor users
- Whether access is attended or unattended
- Whether administrative rights are required
- Whether patient or other sensitive information may be accessed
- Authentication method
- Last review date
- Contract or service end date
- Incident contact
- Access-removal procedure
If the purpose cannot be explained clearly, investigate before allowing the access to continue.
4. Determine whether patient information is involved
Not every software or technology vendor is automatically a HIPAA business associate.
HHS explains that a software vendor generally becomes a business associate when it requires access to protected health information to provide its service. A vendor that merely sells software without accessing PHI may not have that relationship. HHS.gov
When PHI access is involved, leadership should confirm that the appropriate legal and privacy review has occurred and that required agreements are in place before access is provided.
Business-associate determinations and contract language should be reviewed by qualified legal or compliance professionals. Vault can document the technical access but does not provide legal opinions or compliance certification.
5. Require individual accounts
Each vendor technician should use an individually attributable identity whenever the platform supports it.
Avoid generic accounts such as:
-
vendor -
support -
technician -
admin - Shared employee credentials
Individual accounts make it easier to:
- Remove one person without affecting the entire vendor
- Apply the correct permissions
- Review activity
- Investigate unexpected access
- Confirm which technician performed a change
If a shared account cannot be eliminated, document why it exists, who knows the credentials, how the password is protected, and when it is changed.
6. Review authentication
Confirm whether the vendor account uses:
- Multifactor authentication
- A unique password
- A managed vendor identity
- Certificate or device-based controls
- Conditional or location-based restrictions
- Separate administrative credentials
Never allow a vendor to bypass security controls merely because its support process is inconvenient.
If the application cannot support stronger authentication, record the limitation and determine what compensating safeguards are practical.
7. Apply least-privilege access
A vendor should receive only the access required to perform the agreed service.
Ask:
- Does this vendor need administrator rights?
- Does it need access to every workstation?
- Does it need access to patient information?
- Can access be limited to one application, server, location, or department?
- Can file transfer or command execution be restricted?
- Can administrative access be activated only when needed?
- Can access expire automatically?
Broad access may simplify support, but convenience alone does not justify unrestricted permissions.
8. Review remote-support software
Remote-support agents can be installed by:
- Managed IT providers
- EHR vendors
- Billing companies
- Copier vendors
- Imaging providers
- Medical-device companies
- Telecommunications providers
- Individual technicians
For each agent, identify:
- Product name
- Vendor owner
- Devices where it is installed
- Whether unattended access is enabled
- Technician authentication requirements
- Update responsibility
- Available session logs
- File-transfer capability
- Command-execution capability
- Removal procedure
CISA and partner agencies recommend auditing remote-access software and its configuration so organizations can distinguish approved tools from unexpected ones. cisa.gov
Multiple abandoned support agents increase complexity and make unusual activity harder to recognize.
9. Remove former technicians and expired access
Ask each vendor to confirm its current authorized technicians.
Compare that list with:
- Active vendor accounts
- Remote-support groups
- VPN users
- Microsoft 365 guest accounts
- Application administrators
- Physical badges and keys
Disable accounts that no longer have a valid owner or purpose.
Do not wait for the next quarterly review when a technician leaves, a contract ends, or access is no longer required. Those events should trigger immediate action.
10. Review activity and logging
Determine what records are available for:
- Successful and failed sign-ins
- Remote sessions
- Administrative changes
- File transfers
- Account creation
- Permission changes
- Command execution
- Connections outside expected hours
- Connections from unexpected locations
The detail and retention available will vary by product, licensing, and configuration.
Document:
- Which activity is recorded
- How long records are kept
- Who reviews alerts
- Who can retrieve records
- What happens when suspicious activity is identified
A statement that “the system logs everything” is not enough. Confirm what is actually captured and retrievable.
11. Confirm incident-notification expectations
Know how the vendor will notify the organization about:
- Compromised vendor credentials
- Unauthorized access
- A security incident affecting the service
- A vulnerability requiring customer action
- Loss of relevant logs
- A subcontractor incident
- Service unavailability
- Changes to access methods
Record both routine and emergency contacts.
HHS sample business-associate provisions address safeguards, incident reporting, subcontractor obligations, and termination of the relationship. The exact legal requirements depend on the relationship and applicable agreements. HHS.gov
The technology team should know who receives the notification and how it will be escalated outside normal business hours.
12. Plan how access will end
Every vendor record should answer:
- Who requests termination?
- Who disables the accounts?
- Who removes remote agents?
- Who collects keys or equipment?
- Who transfers documentation?
- Who preserves required records?
- Who changes shared credentials?
- Who confirms that data has been returned or handled appropriately?
- Who verifies completion?
Plan for termination before the relationship ends.
A difficult offboarding process is often evidence that the organization does not fully understand the access it granted.
Create a vendor-access register
The review should produce a simple working register.
Recommended fields include:
- Vendor: Legal or operating name.
- Service: Business or clinical function supported.
- Internal owner: Person responsible for the vendor relationship.
- Systems: Applications, devices, or networks the vendor can access.
- Access type: Portal, remote-support tool, VPN, local account, physical access, or integration.
- Vendor users: Named technicians or administrators.
- Privilege level: Standard, elevated, or administrative access.
- Patient-information involvement: Yes, no, or requires review.
- Multifactor authentication: Enabled, unavailable, or requires action.
- Logging: Available activity records and how long they are retained.
- Contract end date: Renewal or termination date.
- Last review: Date and person who completed the review.
- Open action: Correction or follow-up needed.
- Action owner: Person responsible for completing it.
- Due date: Target completion date.
- Status: Open, pending, accepted, or complete.
When should vendor access be reviewed?
Conduct the scheduled review at least quarterly for vendors with meaningful technical or sensitive-data access.
Also review access when:
- A contract starts or ends
- A technician changes
- A vendor changes ownership
- A system is replaced
- A new location opens
- A security incident occurs
- A vulnerability affects the vendor’s product
- Remote access is modified
- An internal owner leaves
- The vendor introduces a subcontractor
- Patient-information access changes
Higher-risk vendors may require more frequent review.
Why This Matters to Healthcare Organizations
Independent medical and dental practices
A small practice may have support agents from its EHR vendor, IT provider, copier company, billing service, and specialty applications installed across the same workstations.
Without one inventory, leadership may not know how many outside access paths exist.
Hospice and home-health providers
Vendors may support mobile devices, remote staff, secure messaging, telehealth, scheduling, and cloud applications.
Access must be reviewed without disrupting field clinicians or after-hours care coordination.
Assisted-living and senior-living organizations
Outside vendors may reach nursing stations, medication-related systems, resident documentation, networks, and communications platforms.
The review should consider shift coverage and the effect of restricting access during a care disruption.
Outpatient clinics
Clinics often depend on several connected vendors for imaging, laboratories, referrals, billing, and practice management.
A failure in one relationship may affect several clinical or administrative workflows.
Healthcare organizations with limited internal IT staff
Smaller organizations may rely heavily on vendor assurances.
Written ownership, access records, and confirmation emails create a more dependable operating process than informal knowledge held by one employee.
Protect, Operate, Recover, and Grow
Protect
- Require named vendor accounts.
- Use multifactor authentication where supported.
- Limit privileges and unattended access.
- Remove former technicians promptly.
- Restrict file transfer and command execution where practical.
- Inventory remote-support agents.
Operate
- Maintain the vendor-access register.
- Assign an internal owner to every relationship.
- Review access quarterly and after triggering events.
- Document exceptions and due dates.
- Keep technical and emergency contacts current.
- Verify that relevant activity can be reviewed.
Recover
- Include critical vendors in downtime and incident plans.
- Maintain alternate contact methods.
- Know how to revoke vendor access quickly.
- Preserve relevant logs and communications.
- Document dependencies before an outage.
- Confirm who supports restoration and validation.
Grow
- Add cybersecurity expectations to new vendor reviews.
- Reduce duplicate or abandoned remote-access tools.
- Integrate vendor offboarding with contract termination.
- Review subcontractor dependencies.
- Use recurring findings to improve purchasing decisions.
- Prioritize vendors based on clinical and operational criticality.
The Bottom Line
Vendor access should be known, owned, limited, reviewable, and removable.
A quarterly review gives healthcare leadership a practical way to confirm who can connect, why access is still needed, which safeguards are present, and what must be corrected.
The goal is not to eliminate vendor support. It is to make every outside access path deliberate and accountable without disrupting patient or resident care.
Frequently Asked Questions
What is a healthcare vendor-access review?
It is a documented review of outside organizations and technicians that can access healthcare facilities, devices, applications, networks, cloud services, or sensitive information.
The review confirms ownership, purpose, permissions, authentication, activity records, and termination procedures.
How often should healthcare vendor access be reviewed?
Quarterly is a practical schedule for vendors with meaningful technical or sensitive-data access.
Access should also be reviewed immediately after personnel changes, contract termination, security incidents, system replacement, or changes to the vendor’s access method.
Does every healthcare vendor need a business associate agreement?
No.
A vendor may be a business associate when its services require it to create, receive, maintain, transmit, or access protected health information. The determination depends on the service and relationship and should receive appropriate legal or compliance review.
Should vendors have administrator access?
Only when administrative access is necessary for the approved service.
The scope, duration, authentication, and activity records should be reviewed. Separate or time-limited administrative access may be appropriate where supported.
Is multifactor authentication enough to secure vendor access?
No.
MFA is important, but it should be combined with named accounts, limited permissions, current software, controlled remote access, activity records, timely account removal, and incident procedures.
Should unattended remote vendor access be allowed?
It may be necessary for some support models, but it should not be enabled by default without review.
Document the business need, devices covered, technician controls, logging, update responsibility, and method for disabling access.
What should happen when a vendor relationship ends?
Disable accounts, revoke active sessions, remove remote agents, recover physical access, change affected shared credentials, transfer documentation, address retained information, and record who verified completion.
Legal and contractual requirements should be reviewed by qualified professionals.
Strengthen Your Vendor-Access Process
Vault Technologies helps healthcare organizations inventory remote-support tools, review Microsoft 365 and Entra ID access, document vendor ownership, coordinate account removal, improve endpoint administration, and prepare practical incident and care-continuity procedures.
Our nurse-led clinical perspective keeps access decisions connected to actual workflows, shift coverage, and patient or resident care. Our veteran-owned approach emphasizes clear ownership, disciplined processes, and reliable follow-through.
Request a complimentary Technology Health Assessment to identify practical gaps in vendor access, identity management, endpoint operations, documentation, backup planning, and care-continuity readiness.
The assessment is a planning tool. It is not a legal opinion, compliance certification, penetration test, forensic investigation, or guarantee against cyber incidents.
Authoritative Sources
- HHS Cyber Gateway — Healthcare and Public Health Cybersecurity Performance Goals, supporting highlight published February 1, 2024.
- HHS — Is a Software Vendor a Business Associate of a Covered Entity?, created December 19, 2002; last reviewed December 28, 2022.
- HHS — Sample Business Associate Agreement Provisions, published January 25, 2013.
- NIST — Cybersecurity Framework 2.0, published February 26, 2024.
- NIST — CSF 2.0 Quick-Start Guide for Cybersecurity Supply Chain Risk Management, published October 21, 2024.
- CISA and Partner Agencies — Identifying and Mitigating Living Off the Land Techniques, published February 7, 2024.
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