Office of Civil Rights Business Associates

News & Analysis as of

Additional Clarification regarding HHS OCR Phishing Email Alert

More information from HHS OCR about the phishing threat... ..On November 28, 2016, the HHS Office for Civil Rights issued a listserv announcement warning covered entities and their business associates about a phishing...more

OCR Alerts Listservs About Fake Phishing Email to Covered Entities and Business Associates

On November 28, 2016, the Office for Civil Rights (OCR) issued an Alert to its listservs that a phishing email is being circulated on “mock HHS Departmental letterhead under the signature of OCR”s Director, Jocelyn Samuels”...more

OCR Issues Alert Regarding Phishing Email Disguised as Official OCR Audit Communication

The U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) published an alert on Nov. 28 describing a phishing email being circulated on mock HHS departmental letterhead under the signature of OCR...more

HHS OCR Alert: Phishing Email Disguised as Official OCR Audit Communication

This alert just in from HHS OCR: “It has come to our attention that a phishing email is being circulated on mock HHS Departmental letterhead under the signature of OCR’s Director, Jocelyn Samuels. This email appears to...more

OCR Warns of Phishing Campaign Disguised as Official OCR Communication

The U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) published an alert on Monday describing a phishing campaign disguised as an email from OCR. The email is being circulated on mock HHS...more

More on HIPAA Audits for 2016 and 2017–Desk Audits and On-Site Audits

As part of the ongoing HHS OCR HIPAA audit initiative, it is conducting “HIPAA desk audits.” These audits don’t involve auditors coming in your facility. Instead, covered entities are being asked to submit documents on...more

OCR Stresses Importance of Authentication in Newsletter

In a recent newsletter, the Office for Civil Rights (OCR) encourages health care organizations to review their procedures around authentication and “ensure that they have the appropriate safeguards in place.”...more

OCR Guidance Underscores Importance of Authentication under HIPAA

In its tenth OCR Cyber Awareness Newsletter of the year (Newsletter), the Office for Civil Rights (OCR) reminded HIPAA-covered entities and business associates of the importance of selecting an appropriate authentication...more

OCR Reminds Companies that Authentication is Key

In non-election news, the Office for Civil Rights (OCR) at the Department of Health and Human Services recently released its November Cyber Awareness Newsletter. This month’s newsletter focuses on the topic of...more

HIPAA Audits – Phase 2: On-Site Audits Scheduled for First Quarter of 2017

Covered Entities and Business Associates may be ringing in the New Year with the prospect of responding to on-site HIPAA audits by federal regulators. The U.S. Department of Health and Human Services Office for Civil Rights...more

Cloud Service Providers Beware, You May Be Subject to HIPAA Without Knowing It

The use of cloud service providers has exploded in the past several years. According to estimates from Gartner, the market for cloud services is expected to reach $204 billion in 2016. But the use of cloud service providers...more

HHS Designates Cloud Service Providers as Business Associates Under HIPAA

Cloud service providers that process electronic protected health information (ePHI) are business associates under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), even if the PHI is encrypted and the...more

Recent HIPAA Settlements Highlight Importance Of Business Associate Agreements

Two related healthcare companies were forced to pay settlements with the federal government totaling over $500,000 over allegations relating to a data breach involving patient health information. Much of the negative...more

How to Avoid Being the Next OCR Target for a HIPAA CMP

In 2016, the Office for Civil Rights (“OCR”) imposed civil monetary penalties (“CMPs”) of over $22.8 million on 12 entities, including a business associate. The most frequent violations of the Health Insurance Portability and...more

OCR Explains How Information Blocking Violates HIPAA

The US Department of Health and Human Services Office for Civil Rights recently posted guidance clarifying that a business associate such as an information technology vendor generally may not block or terminate access by a...more

HHS Publishes New Guidance on HIPAA and Cloud Computing

The U.S. Department of Health and Human Services Office for Civil Rights (OCR) has issued a new guidance regarding HIPAA compliance and the use of cloud computing solutions. The guidance is intended to assist covered entities...more

HHS Issues Guidance Regarding Importance of Business Associate Agreements Between Covered Entities and Cloud Services Vendors

The Health and Human Services Office for Civil Rights (OCR) recently issued guidance regarding the importance of covered entities and cloud service vendors maintaining business associate agreements (BAAs) where electronic...more

Five Highlights from OCR Guidance On HIPAA Compliance In Cloud Computing

The Department of Health and Human Services’ Office of Civil Rights (OCR) has issued guidelines for HIPAA-covered entities that utilize cloud computing in processing electronic protected health information (ePHI). The...more

Health Care System’s HIPAA Security Risk Results in $2.14 Million Fine

On October 18, 2016, the U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR), announced that St. Joseph Health (SJH) agreed to settle allegations relating to the HIPAA Privacy and Security Rules,...more

HHS-OCR Announces Guidance On HIPAA Compliance And Cloud Computing

On October 6, 2016, the Department of Health and Human Services Office for Civil Rights (“OCR”) issued guidance on complying with HIPAA privacy, security, and breach notification rules when using cloud computing technology...more

Failure Under the HIPAA Security Rule Costs $2.14 Million

On October 18, 2016, the Department of Health and Human Services, Office of Civil Rights (“OCR”) announced a $2.14 million settlement with St. Joseph Health (“St. Joseph”), a non-profit integrated Catholic healthcare delivery...more

HHS Publishes Guidance on HIPAA and Cloud Computing

On October 7, 2016, the U.S. Department of Health and Human Services’ Office for Civil Rights (OCR) published guidance to assist cloud service providers (CSPs) and their customers with HIPAA compliance. As discussed below,...more

Just Around the Corner – HIPAA Audits for Business Associates

Financial organizations that are business associates can expect a wave of HIPAA desk audits to evaluate the HIPAA compliance efforts of business associates. These audits have a limited focus and are conducted by the U.S....more

Health Law Insights Newsletter - Issue 13

McCarter & English, LLP’s Health Care Group presents Issue 13 of the Health Law Insights, which discusses the latest legal issues in the health care industry. - Failure to Update Business Associate Agreement Results in...more

OCR Issues Guidance on HIPAA and Cloud Computing

On October 7, 2016, the U.S. Department of Health and Human Services (“HHS”), Office for Civil Rights (“OCR”), released a guidance document (the “Guidance”) on the HIPAA-compliant use of cloud computing technologies. The...more

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