Microsoft Access can support HIPAA-compliant use of electronic protected health information only when it is deployed within a controlled environment that meets HIPAA Security Rule safeguard requirements, uses a HIPAA Business Associate Agreement for any Microsoft-hosted services involved in storing or transmitting the data, and is governed by HIPAA Privacy Rule and HIPAA Minimum Necessary Rule policies that limit access, use, and disclosure.
Microsoft Access is a desktop database application rather than a hosted healthcare service, and it does not provide HIPAA compliance on its own. Compliance depends on how the Access database is designed, where the database file is stored, how users authenticate, how access is restricted, how activity is monitored, and how the organization prevents unauthorized copying or export of protected health information. Access databases stored on unmanaged endpoints, shared drives without role-based permissions, removable media, or personal cloud accounts can place protected health information outside enforceable access controls, audit controls, and retention controls.
Access is frequently deployed alongside Microsoft 365 or Office 365 for identity management, file storage, collaboration, and administration. When protected health information is stored or transmitted using Microsoft-hosted services such as OneDrive for Business, SharePoint, or Exchange Online, a HIPAA Covered Entity or Business Associate needs a HIPAA Business Associate Agreement with Microsoft for in-scope services. Microsoft’s HIPAA compliance materials state, “Office 365 provides HIPAA & HITECH assurances, BAA can be obtained online.” Microsoft is willing to sign a HIPAA Business Associate Agreement for eligible Microsoft 365 and Office 365 services, and the agreement should be in effect before using covered services to create, receive, maintain, or transmit electronic protected health information.
A compliant Access implementation requires administrative and technical controls that match the organization’s risk analysis and risk management decisions. Access to the database file and any connected data sources should be limited to authorized workforce members through unique user identification and strong authentication, with permissions set to enforce job-based access. Audit logging and monitoring should cover file access, exports, and administrative changes when feasible within the chosen architecture. Encryption should protect electronic protected health information at rest and in transit within the storage and transmission pathways selected. Device management controls should address local caching, offline copies, and loss or theft of endpoints that store or can access the database.
Access can be used for limited operational databases that include protected health information when the organization applies HIPAA Security Rule safeguards to the full data lifecycle and relies on Microsoft-hosted services only under an applicable HIPAA Business Associate Agreement.