CCSFP Exam Dumps - Certified CSF Practitioner 2025 Exam

When a requirement statement is marked as Not Applicable (N/A) in MyCSF, HITRUST requires the organization to provide a justification. This justification must be entered into the Subscriber Comments field. The rationale explains why the requirement does not apply to the entity’s environment, systems, or data. For example, if a requirement relates to payment card data but the organization does not process credit cards, the Subscriber Comments field should document that no PCI-DSS scope exists. HITRUST QA reviews these justifications to ensure N/As are applied appropriately. Failure to document rationale can result in QA findings or required CAPs. This requirement preserves transparency and prevents misuse of the N/A designation to exclude applicable controls.

In ani1 assessment, remediated controls must demonstratesustained effectivenessbefore being retested. HITRUST requires a minimum of90 daysbetween remediation and reconsideration of the Implemented maturity level. This waiting period ensures that corrective actions are not only implemented but also consistently applied over time. For example, if patch management processes were deficient and then corrected, HITRUST wants to see proof that the new process has been followed successfully across multiple cycles. Immediate or short-term remediation is insufficient, as it may not show durability. This rule reinforces HITRUST’s focus onoperational maturityand real-world assurance, preventing organizations from implementing “point-in-time fixes” just to pass assessments.

ForPolicy and Procedure maturity levels, HITRUST requires a minimum of30 daysbetween creation or updates and reconsideration for testing in an r2 assessment. This ensures that the policies and procedures are not just newly drafted but have beenapproved, communicated, and adoptedwithin the organization. Thirty days allows time for staff awareness, training, and initial application, which HITRUST views as necessary evidence of operationalization. Unlike Implementation maturity (which requires 90 days of operational evidence for reconsideration), documentation-based maturity levels require a shorter validation window. This distinction reflects the difference between proving written governance documents exist versus proving operational controls function consistently.

When relying onthird-party reports(such as SOC 2 reports) to satisfy HITRUST requirements, only reports with sufficient detail can be used. HITRUST requires:

A cleardescription of scope(A) to confirm applicability to the assessed environment.

Alist of procedures performed(C) so assessors can evaluate whether testing covered relevant controls.

Conclusions reached for each test(E) to provide assurance about the effectiveness of tested controls.

While anexecutive summarymay be helpful for context, it lacks sufficient detail to serve as valid reliance evidence. Similarly, “completed remediation” of exceptions (B) is not required; rather, the report must document exceptions transparently. Assessors remain responsible for verifying that reliance reports are current, relevant, and issued by qualified independent auditors.

HITRUST allows grouping of components to improve efficiency in assessments, but only when there is sufficienthomogeneityamong the components. Grouping is permitted when systems share the sameconfigurations(e.g., identical firewall rule sets, server builds), the samepatch levels(demonstrating equal maintenance and security posture), or whenfacilities use identical access management systems(ensuring consistent physical security practices). The logic behind grouping is that if controls are identical across multiple assets, then one test can represent the whole group without introducing risk. However, grouping must be supported by documentation proving uniformity. If variations exist—for example, one system with different access rules or a facility with a different badge system—those components must be assessed separately. Grouping reduces duplication and workload, but it requires strict evidence of control uniformity to maintain assessment reliability.