David, a member of an external assessor organization, helped his client remediate a control gap. As part of the validation process, David can then review the remediation for appropriateness.
HITRUST enforces a strict separation of duties to maintain assessor independence. External assessors are prohibited from remediating controls for their clients. Their role is to evaluate, test, and validate, not to design or implement fixes. If an assessor directly assists in remediation, they compromise their independence and introduce conflicts of interest. This situation undermines the credibility of the assurance program. In the example, because David assisted in remediation, he cannot objectively validate the effectiveness of the same control. The client would need to use separate consulting resources for remediation while retaining the assessor for independent validation. This rule preserves the integrity and impartiality of the certification process.
[References: HITRUST External Assessor Requirements – “Independence and Objectivity”; CCSFP Practitioner Training – “Assessor Restrictions on Remediation Activities.”, , ]
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