Adam H. Greene

Adam H. Greene

Davis Wright Tremaine LLP

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To Settle or Not to Settle – That Is the Question Raised by Recent HIPAA CMPs

On February 1, 2017, the Department of Health and Human Services, Office for Civil Rights (“OCR”) announced that the Children’s Medical Center of Dallas (“Children’s”) has paid a civil monetary penalty (“CMP”) of $3.2 million...more

2/14/2017 - Civil Monetary Penalty Health Care Providers HIPAA Hospitals OCR PHI

2016 Edition of HIPAA Regulations Released

The Code of Federal Regulations has recently published the 2016 version of the HIPAA regulations. This is the most up-to-date “official” version of the HIPAA regulations....more

2/1/2017 - Cybersecurity Data Security Health Care Providers HHS HIPAA

[Webinar] HIPAA in the Cloud – OCR Guidance on HIPAA and Cloud Service Providers - Jan. 31st, 1:00pm ET

As the health care sector further embraces the benefits of cloud computing, numerous challenges have arisen with applying HIPAA to cloud computing services....more

1/24/2017 - Cloud Computing Cloud Service Providers (CSPs) Covered Entities Data Privacy Data Security Health Care Providers HHS HIPAA Security Breach Webinars

Substance Use Disorder Information: Comments Wanted on Significant Proposed Part 2 Rule

In an unusual action, a Supplemental Notice of Proposed Rulemaking (“SNPRM”) accompanied the recent final rule on 42 C.F.R. Part 2 (“Part 2”) governing the confidentiality of certain substance use disorder information. On...more

1/24/2017 - Comment Period Confidentiality Policies Health Care Providers SAMHSA Substance Abuse

The Price of PHI – A $2.2 Million USB Drive

A stolen unencrypted USB drive led to a $2.2 million settlement and a Resolution Agreement. The Department of Health and Human Services Office for Civil Rights (OCR) announced on January 18th a settlement with MAPFRE Life...more

1/23/2017 - Data Breach Data Security Health Care Providers HHS HIPAA OCR PHI

2017 Health Information Privacy and Security New Year’s Resolutions

To start off the New Year, here are some potential health information privacy and security resolutions. You can use these Annual, Quarterly, and Monthly lists to map out your privacy and security tasks for the year, and then...more

1/11/2017 - Cybersecurity Electronic Medical Records Health Care Providers HIPAA PHI Popular

No Phishing: OCR Warns of Phishing Attempts Disguised as Official HIPAA Audit Program Emails

What’s worse than receiving an email indicating that you have been selected for an audit by your favorite government regulator? Clicking on a link in the email and discovering that it is a phishing attack that has just...more

12/14/2016 - Business Associates Covered Entities Cybersecurity Data Protection Email HHS HIPAA OCR Phishing Scams Popular

OCR Sets Sights on Smaller HIPAA Breaches

Covered entities and business associates can expect increased scrutiny for breaches of unsecured protected health information affecting fewer than 500 individuals. Starting August 2016, the U.S. Department of Health and Human...more

9/8/2016 - Breach Notification Rule Business Associates Covered Entities Data Breach Data Security HHS HIPAA OCR PHI

HIPAA Audit Check-Up – Where We Are and What’s to Come

Phase 2 of the HIPAA audits is fully underway, and covered entities now can take a breath if they have not received a desk audit request. But we still are at the beginning of Phase 2, with more to come. ...more

8/29/2016 - Business Associates Covered Entities HIPAA HIPAA Audits OCR PHI Risk Management

It’s Not the Olympics, but OCR Sets New HIPAA Settlement Records

Athletes at the Rio Olympics aren’t the only ones setting records this year. Hoping to send a “strong message” about the importance of safeguarding electronic protected health information (PHI) and conducting mandated risk...more

8/15/2016 - Business Associates Covered Entities Data Breach HHS HIPAA OCR PHI Risk Management Settlement

Business Associates Beware: First HIPAA Settlement with Business Associate

For the first time, the U.S. Department of Health & Human Services Office for Civil Rights (OCR) has entered into a Resolution Agreement with a business associate over allegations that it potentially violated the Health...more

7/7/2016 - Business Associates HHS HIPAA OCR PHI

HIPAA Enforcement Actions by the Numbers

Protecting patient information is a central duty for both covered entities and business associates under the Health Insurance Portability and Accountability Act (HIPAA). Should a HIPAA-subject entity ever fail to protect...more

6/29/2016 - Breach Notification Rule HHS HIPAA OCR PHI

Tennessee Gives Businesses 45 Days for Data Breach Notice

Recent amendments to the State’s data breach statute give a hard deadline for a business to provide consumer notice, removes encryption safe harbor, exempts entities that are subject to the Health Insurance Portability and...more

4/21/2016 - Cyber Attacks Cybersecurity Data Breach Encryption Gramm-Leach-Blilely Act HIPAA HITECH Incident Response Plans New Legislation Notification Requirements Personally Identifiable Information Safe Harbors

The Audit Protocol is Released, and Other Updated HIPAA Audits News

As we previously reported, the HHS Office for Civil Rights (OCR) launched Phase II of its audit program on March 21. Since that time, a significant amount of new information has emerged, including details regarding the...more

4/12/2016 - Business Associates Covered Entities HHS HIPAA HIPAA Audits OCR

OCR Phase 2 HIPAA Audits Are Here: What to Expect While You’re Expecting (an Audit)

The Phase 2 audit program for HIPAA compliance is under way. The U.S. Department of Health and Human Services’ Office for Civil Rights (OCR) announced that it had launched the Phase 2 audits to examine and assess how covered...more

3/29/2016 - Breach Notification Rule Business Associates Covered Entities Health Care Providers HIPAA HIPAA Audits HIPAA Breach OCR PHI

Can Ransomware Trap Your Health Information? OCR Highlights the Risk of Cyber Extortion in its Cyber-Awareness Initiative

The U.S. Department of Health and Human Services’ Office for Civil Rights (OCR) has been highlighting the threat posed by “ransomware”—when an organization is locked out of its own systems and files by cyber criminals who...more

2/23/2016 - Cyber Attacks Cyber Crimes Cyber Insurance Health Care Providers Malware OCR Ransomware Risk Mitigation

One Step Forward and Two Steps Back: Proposed Changes to the Alcohol and Drug Abuse Treatment Confidentiality Rule

On Feb. 9, 2016, the U.S. Department of Health and Human Services Substance Abuse and Mental Health Services Administration (SAMHSA) published in the Federal Register a proposed rule putting forth amendments to the Alcohol...more

2/16/2016 - Confidential Documents Drug & Alcohol Abuse Health Care Providers HIPAA Medical Records Privacy Rule SAMHSA

Second CMP Assessed for HIPAA Violations: Do You Know Where Your Data Is?

For only the second time in its history, the U.S. Department of Health and Human Services’ (HHS) Office for Civil Rights (OCR) has imposed a civil money penalty (CMP) on a covered entity for allegedly violating the HIPAA...more

2/10/2016 - ALJ Civil Monetary Penalty Corporate Counsel Covered Entities HHS HIPAA OCR PHI Privacy Rule

As if a 20-Year Consent Order Wasn’t Enough Fun: FTC Brings First Monetary Settlement in Information Security Case

The FTC reached a $250,000 settlement with a 20-year consent order with Henry Schein Practice Solutions, Inc. over its use of allegedly subpar encryption technology in its offering to dental practices. This settlement is...more

1/7/2016 - Data Breach Encryption FTC HIPAA NIST Settlement

You Can’t Take It with You – NY Attorney General Reaches Settlement over Exiting Clinician Taking Patient List

It may not be a big dollar amount ($15,000), but a recent New York Attorney General settlement represents a big issue—interpreting that HIPAA prohibits a health care professional who is changing practices from taking a...more

12/15/2015 - Attorney Generals Continuity of Care Health Care Providers HIPAA Nurse Practitioners Patient Privacy Rights

Confusion Continues Over Medical Identity Theft Victim Rights under HIPAA

In a Nov. 10, 2015 letter, the Chairs and Ranking Members of the Senate Committee on Health, Education, Labor, and Pensions and the Committee on Finance raised concerns with the U.S. Department of Health and Human Services...more

12/2/2015 - HHS HIPAA Identity Theft Medical Records Personally Identifiable Information Popular

Are Attorneys Entitled to “HIPAA Rate”?

Over the past year, numerous lawsuits and complaints to the HHS Office for Civil Rights (“OCR”) have been filed by plaintiffs’ attorneys over a seemingly obscure HIPAA issue – the rate that health care providers and their...more

11/6/2015 - Fees FOIA Health Care Providers Healthcare HHS HIPAA Medical Records OCR Privacy Rule Release of Information

[Webinar] Mobile Device Management for Health Care Organizations and Vendors - Sept. 10th, 10:00am PDT

In this webinar, we will demystify the HIPAA Security Rule and how to apply the administrative, physical, and technical safeguards in a mobile environment. We will discuss key takeaways from the recently released NIST Draft...more

9/4/2015 - Data Breach Data Protection Data Security Electronic Medical Records HIPAA mHealth Mobile Apps Mobile Devices NIST Patient Privacy Rights Popular Webinars

Be Careful with Information Destruction: Another Medical Record Disposal HIPAA Settlement

The U.S. Department of Health and Human Services Office for Civil Rights (“OCR”) recently announced a new settlement with a small pharmacy, Cornell Prescription Pharmacy (“Cornell”). OCR alleged that Cornell was disposing of...more

5/1/2015 - Document Destruction Enforcement Actions OCR Pharmacies PHI Settlement

Employers: What the Anthem Breach Means to You

On Feb. 4, 2015, Anthem announced a data breach involving the personal information of more than 80 million individuals resulting from what it characterized as a sophisticated, targeted cyber-attack. Group health plans may be...more

2/10/2015 - Anthem Insurance Best Practices Breach Notification Rule Corporate Counsel Cyber Attacks Cybersecurity HIPAA Personally Identifiable Information

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