How to Automate HITRUST r2 Evidence Collection for SaaS Vendors

Achieving HITRUST r2 certification is often the definitive requirement for SaaS vendors selling to hospitals, payers, and healthcare providers. Unlike SOC 2, a HITRUST r2 validated assessment requires prescriptive evidence across 19 control domains within the CSF (Common Security Framework). While cloud infrastructure controls can be partially automated via API, the application-level controls—requiring screenshots, process documentation, and "Implemented" maturity evidence—often stall certification for months. Automating HITRUST evidence collection is the only way to meet these rigorous demands without dedicating your entire engineering team to audit preparation.

Why Do Healthcare Buyers Demand HITRUST r2?

Answer: Healthcare organizations demand HITRUST r2 because it provides a higher level of assurance than HIPAA self-assessments or SOC 2 reports. The HITRUST CSF harmonizes requirements from HIPAA, NIST, ISO 27001, and GDPR into a single framework with prescriptive controls. For SaaS vendors, an r2 certification proves that controls are not just designed (as in SOC 2 Type I) but are effectively implemented, measured, and managed over a 12-month period.

The complexity of HITRUST lies in its maturity model. Assessors do not just ask "Do you have a policy?"; they ask for five levels of evidence:

Policy: Do you have a written rule?
Procedure: Is there a documented process?
Implemented: Is the control actually working? (Requires screenshots/logs).
Measured: Do you test it?
Managed: Do you fix it when it breaks?

Automation is critical for levels 3, 4, and 5, where manual screenshot collection becomes unmanageable at scale.

What Evidence Do HITRUST Assessors Require for r2 Certification?

HITRUST assessors require specific artifacts to validate "Implementation" maturity. This evidence must be recent, relevant, and verifiable.

1. Access Control (Domain 01)

Controls regarding user registration, privilege management, and review.

Requirement	Required Evidence (Artifacts)	Automation Method
01.b User Registration	Screenshots of the admin dashboard showing unique IDs and registration workflows.	Screenata / Workflow Recorder
01.c Privilege Mgmt	Screenshots of role definitions and "Access Denied" errors for unauthorized users.	Workflow Recorder
01.y Remote Access	Logs and screenshots showing MFA enforcement and VPN session timeouts.	API + Console Screenshot

2. Audit Logging & Monitoring (Domain 09)

Controls ensuring activity is recorded and reviewed.

Requirement	Required Evidence (Artifacts)	Automation Method
09.aa Audit Logging	Screenshots of log configurations (e.g., CloudTrail, Splunk) showing retention settings.	API Monitor
09.ab Monitoring	Evidence of automated alerts (screenshots of Slack/PagerDuty integrations).	API + Screenshot

3. Vulnerability Management (Domain 10)

Controls for patching and scanning.

Requirement	Required Evidence (Artifacts)	Automation Method
10.m Control of Vulns	Screenshots of recent scan reports and tickets showing remediation within SLAs.	API + Workflow Recorder
10.l Malicious Code	Screenshots of endpoint protection (EDR) agents active on sample devices.	MDM API / Screenshot

4. Configuration Management (Domain 06)

Controls ensuring systems are configured securely.

Requirement	Required Evidence (Artifacts)	Automation Method
06.d Change Management	Screenshots of Pull Requests (PRs) showing approvals and CI/CD pipeline success.	API (GitHub/GitLab)
06.e Config Standards	Screenshots of "Golden Image" baselines or Terraform state files.	API + Screenshot

What is the Difference Between HITRUST e1, i1, and r2?

SaaS vendors must choose the right assessment level based on their client's risk appetite.

Assessment Type	Scope & Focus	Evidence Burden	Automation Need
e1 (Essentials)	~44 Controls. Basic cyber hygiene.	Low. Focus on policies and basic configs.	Low
i1 (Implemented)	~219 Controls. Leading security practices.	Medium. Requires proof of implementation (screenshots).	High
r2 (Risk-based)	200–800+ Controls. Comprehensive risk mgmt.	Severe. Requires evidence for Policy, Procedure, and Implementation across all domains.	Critical

Most enterprise healthcare systems (Payers/Providers) require vendors to hold HITRUST r2 certification.

Where Traditional HITRUST Assessment Automation Falls Short

Many SaaS vendors attempt to use general GRC tools like Drata or Vanta for HITRUST. While these tools are excellent for SOC 2, they struggle with the depth of HITRUST MyCSF requirements.

The Automation Gap:

MyCSF Specificity: HITRUST requires evidence mapped to specific requirement statements (e.g., "09.m"). Generic GRC tools often map evidence loosely to "Access Control," which assessors reject.
Application-Level Visibility: GRC tools monitor cloud APIs (AWS/Azure). They cannot see inside your SaaS application's admin panel to verify how your customers' data is segregated or how your internal support tools enforce least privilege.
Maturity Scoring: proving "Measured" and "Managed" maturity requires time-series data—showing that a control was tested quarterly and issues were remediated. A single API check ("Is MFA on?") does not satisfy this.

The Solution: You need evidence automation agents like Screenata that can record workflows, capture UI-based evidence, and generate structured reports that external assessors can upload directly to the MyCSF portal.

How to Automate HITRUST r2 Evidence Collection

Automating HITRUST evidence involves capturing the "Implementation" artifacts that APIs miss.

Step 1: Map Your Scope in MyCSF

Determine your requirement set based on risk factors (volume of records, regulatory factors). Export your requirement list.

Step 2: Deploy Evidence Agents

For controls requiring visual proof (e.g., Domain 01 Access Control, Domain 10 Vulnerability Management), configure Screenata to record the validation steps.

Action: Record a quarterly access review of the production database.
Automation: The agent navigates the user list, captures screenshots of permissions, and logs the review timestamp.
Output: A PDF containing the screenshots, tester identity, and control mapping.

Step 3: Automate "Negative Testing"

HITRUST assessors love "negative testing" (proving controls block unauthorized actions).

Manual: Create a test user, try to access admin settings, take a screenshot of the error.
Automated: Screenata runs a script that attempts unauthorized access, captures the "403 Forbidden" screen, and packages it as evidence for Requirement 01.c.

Step 4: Continuous Collection

Schedule these automations to run monthly. When the external assessor arrives, you will have 12 months of consistent, timestamped evidence, satisfying the "Measured" and "Managed" maturity levels.

Example: Automating Access Control Evidence (Requirement 01.b)

Requirement Statement: "The organization ensures that a unique identifier (User ID) is assigned to each user... and that the registration process includes verification of authorization."

Manual Evidence Workflow:

Log into Identity Provider (Okta/Auth0).
Screenshot user list showing unique IDs.
Find a recent new hire ticket in Jira.
Screenshot the approval on the ticket.
Combine into a PDF and upload to MyCSF.

Automated Evidence Workflow:

Trigger: New user added to Okta.
Screenata Agent:
- Captures screenshot of Okta user profile creation.
- Fetches linked Jira ticket via API.
- Captures screenshot of Jira approval workflow.
Result: Generates evidence_01b_user_registration.pdf automatically and stores it in your evidence library.

Can You Inherit Evidence from AWS or SOC 2?

Inheritance: Yes, HITRUST allows "inheritance" of controls from cloud providers (AWS/Azure/GCP). If AWS is HITRUST certified, you can inherit physical security controls (Domain 11) and some network controls.

Action: Submit an inheritance request in MyCSF.
Limitation: You cannot inherit controls for your application logic or your employee access.

Reliance: You can "rely" on SOC 2 evidence, but it must be re-mapped. A SOC 2 screenshot for "CC6.1" might satisfy HITRUST "01.b," but it needs to be formatted and tagged correctly for the HITRUST assessor. Automation tools handle this re-mapping effectively.

Frequently Asked Questions

How long does HITRUST r2 certification take?

Traditionally, 9–12 months. With automated evidence collection, vendors can reduce the readiness and remediation phase to 6–8 weeks, followed by the mandatory 90-day validation period.

Can I use Drata or Vanta for HITRUST?

Yes, as a management platform. However, you will likely need an additional evidence automation tool to capture the deep, application-level screenshots and process documentation that Drata/Vanta APIs do not cover.

Does HITRUST cover HIPAA compliance?

Yes. HITRUST CSF includes all HIPAA Security and Privacy Rule requirements. Achieving HITRUST r2 certification is widely accepted as the "gold standard" proof of HIPAA compliance for Business Associates.

Key Takeaways

✅ HITRUST r2 is the standard for selling SaaS to healthcare enterprise buyers.
✅ Evidence Requirements are prescriptive: you need proof of Policy, Procedure, and Implementation.
✅ Manual Screenshots for 19 domains are unsustainable; automation is required for scale.
✅ Inheritance helps with infrastructure, but application controls must be documented by the vendor.
✅ Automation Agents can capture MyCSF-ready evidence (screenshots + metadata) that general GRC tools miss.

Learn More About HITRUST r2 Certification Evidence Automation

For a complete roadmap to certification, see our guide on automating HITRUST r2 evidence collection, including detailed strategies for mapping evidence to MyCSF requirements.