Breach Notification Rule Business Associates

News & Analysis as of

HHS OCR Guidance on Ransomware Attacks: They Constitute a “Security Incident” and Are Likely a Data Breach

On July 11, 2016, the HHS Office of Civil Rights (OCR) released guidance on HIPAA covered entities’ responsibilities in a ransomware attack, a type of cyber-attack that has targeted the health care sector extensively in...more

Ransomware Attack is a Breach – Unless You Can Prove Otherwise

Ransomware is the fastest growing malware threat in the United States, targeting simple home computers to elaborate corporate IT networks. The Federal Bureau of Investigation recently reported an increase in ransomware...more

Regulatory Authorities Launch The Second Phase Of The HIPAA Compliance Audit Program

As a part of its continued efforts to assess compliance with the Health Insurance Portability and Accountability Act (HIPAA) Privacy, Security, and Breach Notification Rules, the Health and Human Services (HHS) Office for...more

The Long Anticipated HIPAA Audits Are Here!

Phase 2 HIPAA Audits, which the Department of Health and Human Services' Office of Civil Rights ("OCR") announced had "launched" back in March of this year, have now officially begun. On Monday, July 11, 2016, the first round...more

OCR Begins HIPAA Phase 2 Audits

What covered entities and business associates can do to prepare for the next round of audits. On July 11, the HIPAA Phase 2 audits commenced when 167 covered entities received notice of a desk audit from the Department...more

OCR Sends Notification Letters to Phase 2 HIPAA Auditees

On July 12, 2016, HHS’s Office for Civil Rights (OCR) distributed an e-mail discussing recent developments in Phase II of its HIPAA audit program....more

Entity Fined $650,000 in First HIPAA Settlement with a Business Associate

The possibility of business associates potentially being audited, investigated, and ultimately fined is now a reality. On June 24, 2016, the United States Department of Health and Human Services’ Office of Civil Rights...more

OCR Update: HIPAA Phase 2 Audit Notices—Responses Due July 22, 2016

On July 11, 2016, e-mail notification was sent to 167 covered entities alerting them of their inclusion in the desk audit portion of OCR’s 2016 HIPAA audit program. Selected covered entities must respond no later than July...more

HIPAA Phase 2 Audits: Actions Not Just Words

Action Item: With the commencement of Health Insurance Portability and Accountability Act (“HIPAA”) Phase 2 audits, and the increase in HIPAA enforcement activity, covered entities and business associates need to take HIPAA...more

New HIPAA Phase 2 Audits: Targets Notified by Email Only

The U.S. Department of Health and Human Services Office for Civil Rights (OCR) recently announced the long-awaited launch of Phase 2 of its HIPAA Audit Program (Phase 2 Audits). The Phase 2 Audits will review the policies...more

OCR Releases Updated HIPAA Audit Protocol and Business Associate Listing Template

The Office of Civil Rights (OCR) recently updated the audit protocol that it will be using to assess Covered Entities’ and Business Associate’s compliance with the Health Insurance Portability and Accountability Act (HIPAA)...more

OCR issues audit protocol and targets over 800 entities—business associates too

The Office for Civil Rights (OCR) has issued its revamped audit protocol for its second phase of auditing covered entities and business associates’ compliance with the HIPAA Privacy, Security and Breach Notification Rules....more

How to Prepare for the Next Round of HIPAA Audits

Nearly two years after the Office of Civil Rights (“OCR”) first announced its preparation for another round of HIPAA audits, Phase II of OCR’s HIPAA audit program is finally underway. On March 21, OCR began emailing...more

HIPAA Audits Coming Your Way – Are You Ready?

The Office of Civil Rights (OCR) of the Department of Health and Human Services has begun Phase 2 of its audit program under the Health Insurance Portability and Accountability Act (HIPAA). In this phase, OCR will: -...more

Employee Benefits & Executive Compensation Advisory: So You Heard About HIPAA Phase 2 Audits. What Should You Do Now?

As you may have recently read (for example, “HHS/OCR Announces Launch of HIPAA Audit Program Phase 2”), the U.S. Department of Health and Human Services’ (HHS) Office for Civil Rights (OCR) has started “Phase 2” of its audit...more

OCR Announces Beginning of 2016 HIPAA Phase 2 Audit Program

The OCR recently announced the beginning of the next phase of the HIPAA Privacy, Security, and Breach Notification Audit Program and indicated that it will review the policies and procedures implemented by covered entities...more

Have You Checked Your SPAM Folder Recently?

Nearly two years after the Office of Civil Rights (“OCR”) first announced its preparation for another round of HIPAA audits, Phase II of OCR’s HIPAA audit program is finally underway. On March 21, OCR began emailing...more

Be Prepared: Phase 2 HIPAA Audits Set to Begin

On March 21, 2016, the U.S. Department of Health and Human Services, Office for Civil Rights (“OCR”), announced the launch of the 2016 Phase 2 Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) Audit...more

HIPAA Audits Are Here: What to Expect When You are 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

Health Care and Long-Term Care News Groups: The HIPAA Phase 2 Audits Have Arrived

The Department of Health and Human Services Office of Civil Rights (OCR) has commenced the long-anticipated HIPAA phase 2 audits, and with it may come an uptick in HIPAA enforcement efforts. All providers and business...more

Next Phase of HHS Office for Civil Rights HIPAA Audits

On March 21, 2016, the U.S. Department of Health and Human Services, Office for Civil Rights (“OCR”) announced that it has begun its phase 2 Health Insurance Portability and Accountability Act (“HIPAA”) audit program. In...more

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

Phase 2 of HIPAA Audits Is Underway – Covered Entities and Business Associates Beware

The U.S. Department of Health and Human Services Office of Civil Rights (OCR) recently announced that it has started obtaining and verifying entity contact information to identify covered entities and business associates for...more

HHS’ Selection of Contractor Provides Latest Update on Impending Second Round of HIPAA Audits

On October 27, 2015, a U.S. Department of Health and Human Services (“HHS”) official stated that the agency has hired FCi Federal, a provider of management and professional services to government agencies in Ashburn, VA, to...more

HIPAA Double Take: What Health Plan Sponsors Need to Know Now

With the onslaught of Affordable Care Act changes, health plan sponsors have much to think about lately. Given the number of other issues affecting them, plan sponsors may feel that HIPAA privacy and security is an issue they...more

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