OUR THOUGHTS ON:

SOC 2 Reports Meet Certification Program Requirements for Access to the Death Master File

Risk Advisory/Internal Audit|SSAE 18/SOC

By Troy Fine

On June 1, 2016, the National Technical Information Service (NTIS) issued the final rule for how entities receiving the Limited Access Death Master File (LADMF) become certified prior to being granted access to the LADMF.  The final rule, "Certification Program for Access to the Death Master File," requires that applicants requesting LADMF access demonstrate that they have adequate information technology (IT) security controls in place to safeguard the data once it is received.

When applying for access to the LADMF, an entity must include in the application package a written attestation and assessment report from an Accredited Conformity Assessment Body that attests that the entity has systems, facilities, and procedures in place to meet the security control and safeguard requirements of the final rule.  NTIS developed Information Security Guidelines to provide entities with assistance in complying with the information security requirements of the final rule.

Under the final rule, CPA firms are considered Accredited Conformity Assessment Bodies, and SOC 2 Reports are considered acceptable assessment reports for providing evidence that the entity requesting access to the LADMF is complying with the requirements of the final rule.

The final rule will go into effect as of November 28, 2016.  Entities submitting applications on or after this date will be required to submit a written attestation report, such as a SOC 2 Report, from an Accredited Conformity Assessment Body, such as a CPA firm.

Please contact us with questions on how to comply with the security requirements of the final rule and visit our SOC page for more information on SOC reports and how they can help your organization.

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