Data Breach Business Associates

News & Analysis as of

HIPAA and $15 Million in 2016

For years, many questioned whether the HIPAA privacy and security rules would be enforced. The agency responsible for enforcement, Health and Human Services’ Office for Civil Rights (OCR), promised it would enforce the rules,...more

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

OCR Announces First HIPAA Enforcement Action against a Business Associate

The U.S. Department of Health and Human Services Office for Civil Rights (OCR) announced an agreement with Catholic Health Services of the Archdiocese of Philadelphia (CHCS), settling allegations that CHCS violated the Health...more

OCR Issues New Guidance on Ransomware and HIPAA

In response to a rising number of ransomware attacks on healthcare systems, the Department of Health and Human Services (HHS) Office of Civil Rights (OCR) has issued new ransomware guidance on the HIPAA obligations of...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

Oregon Health & Science University pays $2.7M penalty for data breaches

Oregon Health & Science University (OHSU) has agreed to settle alleged HIPAA violations involving two separate data breaches with the Office for Civil Rights (OCR) for $2.7 million. In the span of three months in 2013,...more

Recent Enforcement Action: Business Associates Not Off the Hook

Despite the fact that Business Associates have been directly subject to and liable under the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (HIPAA) since February 18, 2010 the...more

BYOD Risks under HIPAA – Does Your HIPAA Compliance Program Adequately Address the Ever Increasing Use of Portable Electronic...

Many U.S. employers are now allowing employees to use their own personal handheld devices and laptop computers for work-related purposes. As the age of employer-provided devices is coming to an end and “bring your own device”...more

Business Associate Settles HIPAA Investigation for $650,000

The U.S. Office for Civil Rights (OCR), the agency responsible for enforcing the HIPAA Privacy and Security rules, has just sent a strong message that business associates are not immune from scrutiny. On June 24, 2016, in a...more

Recent Settlements and Upcoming Audits Highlight the Continuing Need to Focus on Core HIPAA Compliance Measures

Recent settlements and initiatives conducted by the Office for Civil Rights ("OCR") at the U.S. Department of Health and Human Services highlight the continuing need for focus on compliance with the privacy and security...more

What's New with HIPAA?

A number of new developments have taken place related to Health Insurance Portability and Accountability Act (HIPAA) privacy and security compliance, and enforcement is increasing. Healthcare providers, health plans and other...more

Settlements reached for PHI Disclosures

In the last two months, the U.S. Department of Health and Human Services (“HHS”) announced two settlement agreements involving the disclosure of protected health information ("PHI"). In both instances, the health care...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

Department of Health and Human Services Cracks Down on Vendor Oversight in Recent Hospital Settlements

From the rise in ransomware attacks to inadvertent disclosure of information by subcontractors, the health services industry is reminded that a potential consequence of a data breach is the threat of a regulatory enforcement...more

How Recent Cybersecurity Government Publications Impact HIPAA Security Compliance and the New Audit Initiative

Cybersecurity Impacts on HIPAA Security Compliance and the New Audit Initiative - New Audit Initiative Items to Watch - While The HHS Office for Civil Rights recently announced its intent to perform a second...more

HHS OCR Announces Launch Of Long-Awaited Phase 2 HIPAA Audit Program

On March 21, 2016, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced the launch of its Phase 2 HIPAA compliance audits pursuant to which it will audit covered entities and...more

OCR Launches Phase 2 of HIPAA Audits

Five suggested steps healthcare organizations and their contractors should take to prepare. On March 21, the Office of Civil Rights (OCR) of the Department of Health and Human Services launched Phase 2 of the HIPAA Audit...more

Seven-Figure Settlement Reinforces Necessity of Business Associate Agreements

On March 16, 2016, the U.S. Department of Health and Human Services, Office for Civil Rights (“OCR”) announced that North Memorial Health Care of Minnesota (“Memorial”) agreed to pay $1.55 million to resolve allegations that...more

Data-Harvesting Zombie Hackers, Blood-Thirsty Auditors, and Other Reasons to be Scared on Halloween

This Halloween, the scariest monsters might not be in your closet or under your bed. They may be overseas, orchestrating intrusions into your electronic medical record. Or they may be lurking in your own workforce, carrying...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

Blog: HHS To Launch New HIPAA Audits in Early 2016 in Response to OIG Reports

The Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) issued two reports yesterday calling for the HHS Office of Civil Rights (OCR) to strengthen its Health Insurance Portability and...more

Cure of Security Rule Violations Following Breach of EPHI Cannot Save Covered Entities from $750,000 Settlement; Non-Breach...

More than three years after the Cancer Care Group, P.C. (“CCG”) notified the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) of a breach of unsecured electronic protected health...more

Crafting a more realistic business associate agreement

According to a recent survey by KPMG, eighty percent (80%) of health care executives report that their information technology systems have been compromised by cyber attacks. Most healthcare institutions, the survey found,...more

St. Elizabeth’s Medical Center Pays $218,400 to Settle Alleged HIPAA Security Case Stemming from Use of Cloud-Based Document...

Alleged HIPAA Violations Resulted from Medical Center’s Failure to Risk Assess Internet-Based Document Sharing Application and Inadequate Breach Response. The US Department of Health and Human Services (HHS) Office for...more

Back to School – HIPAA 101

After a summer that saw major data breaches at the Office of Personnel Management and UCLA Health System, this fall is a great time to take your organization back to school on HIPAA compliance and data security. Here are...more

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