Migration from EDE to ARC-AMPE Incident Response Controls

This white paper serves as a guide for Direct Enrollment Entities (DEEs) to transition their Enhanced Direct Enrollment (EDE) System Security and Privacy Plans (SSPPs) to the Acceptable Risk Controls for ACA, Medicaid, and Provider Entities (ARC-AMPE). It specifically addresses the Incident Response controls within the ARC-AMPE framework. The document outlines the purpose of the migration, which is to enhance compliance with federal regulations and improve the security of consumer data. It details the oversight role of the Centers for Medicare & Medicaid Services (CMS) in ensuring DEEs adhere to strict security and privacy control requirements. Additionally, the paper presents a comparison of the control families between EDE and ARC-AMPE, highlighting the increased number of controls and changes in documentation format. The Incident Response section elaborates on the necessary policies, procedures, and training required for effective incident management, emphasizing the importance of regular updates and compliance with CMS guidelines.