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CRISC Practice Question: A healthcare organization is implementing a new…
A healthcare organization is implementing a new electronic health records (EHR) system. During the risk assessment, the risk practitioner discovers that the system's access control mechanism allows any authenticated user to view patient records without additional authorization checks. This violates the principle of least privilege and could lead to unauthorized disclosure of protected health information (PHI). The IT team proposes implementing role-based access control (RBAC), but it will require significant changes to the system configuration and user training. The project manager is concerned about delays to the go-live date. The organization has a moderate risk appetite but must comply with HIPAA regulations. Which of the following actions should the risk practitioner recommend FIRST?
⚠ Common exam trap
Many candidates choose 'accept the risk' (A) or 'delay go-live' (D) because they focus on either risk appetite or compliance in isolation, failing to recognize that compensating controls can bridge the gap between operational urgency and regulatory requirements.
Answer choices
Why each option matters
Answer the question above first, then reveal the full breakdown to understand why each option is right or wrong.
Correct answer & explanation
✓
Implement a temporary compensating control, such as logging and monitoring all accesses to patient records, and proceed with go-live while RBAC is developed.
It balances the immediate need to go live with the critical requirement to protect PHI. Logging and monitoring all accesses acts as a detective compensating control, providing visibility into unauthorized disclosures while the more robust RBAC preventive control is developed. This approach aligns with the organization's moderate risk appetite and HIPAA compliance obligations by not accepting the risk outright, but also not delaying the project unnecessarily.
Answer analysis
Option-by-option breakdown
For each option: why learners choose it and why it is or isn't the right answer here.
- ✗
Accept the risk because the likelihood of unauthorized access is low.
Why it's wrong here
Likelihood is not low; vulnerability is significant.
- ✓
Implement a temporary compensating control, such as logging and monitoring all accesses to patient records, and proceed with go-live while RBAC is developed.
Why this is correct
Compensating controls reduce risk while avoiding delays.
- ✗
Proceed with the go-live as scheduled and plan to implement RBAC in a future upgrade.
Why it's wrong here
No compensating control leaves PHI exposed.
- ✗
Delay the go-live until RBAC is fully implemented to ensure compliance.
Why it's wrong here
Unnecessary delay when compensating controls are available.
Quick reference
Access Control Model Comparison
| Model | Acronym | Who Controls Access? | Best For |
|---|---|---|---|
| Discretionary Access Control | DAC | Resource owner | Small teams, file shares |
| Mandatory Access Control | MAC | System / security labels | Classified govt / military |
| Role-Based Access Control | RBAC | Administrator (via roles) | Enterprise environments |
| Attribute-Based Access Control | ABAC | Policy engine (user + resource attributes) | Fine-grained, dynamic policies |
| Rule-Based Access Control | RuBAC | System rules / ACLs | Firewall rules, network ACLs |
Go deeper
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Written by Johnson Ajibi, MSc IT Security
Senior Network & Security Engineer · founder of Courseiva
This CRISC practice question is part of Courseiva's free ISACA certification practice question bank. Courseiva provides original exam-style practice questions with explanations, topic-based practice, mock exams, readiness tracking, and study analytics to help learners prepare for the CRISC exam.