Office of Civil Rights Business Associates

News & Analysis as of

OCR Launches Phase 2 HIPAA Audit Program with Pre-Audit Screening Surveys

Health Insurance Portability and Accountability Act of 1996 (HIPAA) covered entities have reported that the U.S. Department of Health and Human Services Office for Civil Rights (OCR) recently sent pre-audit screening surveys...more

OCR Transmits Pre-Audit Screening Surveys to Covered Entities for Phase 2 HIPAA Compliance Audits

The U.S. Department of Health and Human Services, Office for Civil Rights (OCR) recently transmitted HIPAA pre-audit screening surveys to covered entities that may be selected for a second phase of HIPAA compliance audits...more

ONC Releases Privacy and Security Guidance Geared Toward Small Providers

The HHS Office of the National Coordinator for Health Information Technology (“ONC”) recently released a new and improved version 2.0 of their Guide to Privacy and Security of Electronic Health Information. This revamped...more

OCR Enforcement of HIPAA Affects Entities of all Sizes Small Pharmacy Enters into Latest Settlement

U.S. Department of Health and Human Services (HHS) announced late last week that Cornell Prescription Pharmacy (Cornell) agreed to settle potential violations of the Health Insurance Portability and Accountability Act of 1996...more

OCR Announces Another HIPAA Settlement and Warns Not to Forget About Paper Records

On April 27, 2015, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced that Cornell Prescription Pharmacy (“Cornell Pharmacy”) had entered into a resolution agreement to settle,...more

2015 Phase Two HIPAA Audits – Delayed Again

Recently, the Director of the Department of Health and Human Services Office for Civil Rights (“OCR”) confirmed that OCR is still working to finalize the procedures for “Phase Two” HIPAA audits. OCR had initially planned to...more

Office of Civil Rights Delays Phase 2 Audits

The Office of Civil RIghts (“OCR”) recently announced that Phase 2 of the HIPAA audits would be further delayed because the audit portals and project management tools that are needed to initiate the audit process are not...more

Pressure Points: OCR Enforcement Activity in 2014

During 2014, the Office for Civil Rights (OCR) of the U.S. Department of Health & Human Services initiated six enforcement actions in response to security breaches reported by entities covered by the Health Insurance...more

HIPAA Settlement Underscores the Vulnerability of Unpatched and Unsupported Software

The title of this alert, which comes straight from the Department of Health and Human Services Office for Civil Rights' (OCR) announcement of its most recent settlement, again underscores the critical need for covered...more

Recent HHS Settlement Highlights Importance of Updating HIPAA Compliance Programs

On December 8, 2014, the U.S. Department of Health and Human Services' (HHS) Office for Civil Rights (OCR) announced a resolution agreement with Anchorage Community Mental Health Services, Inc. (ACMHS). The agreement, which...more

Anchorage Community Mental Health Services to Pay $125,000 in Newest HIPAA Settlement: Covered Entities and Business Associates...

Anchorage Community Mental Health Services, Inc. (“ACMHS”) will pay $125,000 to the United States Department of Health and Human Services, Office for Civil Rights (“OCR”) to settle alleged violations of the Health Insurance...more

Preparing for HIPAA Compliance Audits

The U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR), the office responsible for administering and enforcing the Health Insurance Portability and Accountability Act of 1996 (HIPAA), will...more

HIPAA Privacy in Emergency Situations

In light of the Ebola outbreak and other events, the U.S. Department of Health and Human Services, Office for Civil Rights, released a bulletin to ensure HIPAA covered entities are aware of the ways in which patient...more

HHS Issues Special HIPAA Guidance for Ebola Outbreak

The U.S. Department of Health and Human Services ("HHS"), Office for Civil Rights ("OCR"), released a bulletin last week addressing how covered entities (including certain health care providers and employer group health...more

Data, Privacy & Security Practice Report – Also in the News: November 2014

Office for Civil Rights Releases HIPAA Bulletin in Light of Ebola Outbreak – The U.S. Department of Health and Human Services Office for Civil Rights released a bulletin today reminding HIPAA covered entities and...more

OCR Publishes Bulletin Regarding Privacy in Light of Ebola Outbreak

In response to the recent Ebola outbreak in West Africa and in light of patients being treated in several hospitals in the U.S., the HHS, OCR (OCR) recently issued a HIPAA Bulletin to remind us that HIPAA covered entities and...more

Health Care Providers Responding to Ebola: HHS Issues Guidance Reminding Covered Entities that HIPAA Allows the Sharing of PHI in...

The Department of Health and Human Services (“HHS”) Office of Civil Rights (“OCR”) has issued guidance to remind HIPAA-covered entities of the ways in which they are permitted under HIPAA to share protected health information...more

OCR’s New Bulletin on Ensuring Privacy in Public Health Emergencies

This week, the HHS Office of Civil Rights (OCR) issued a bulletin (Bulletin) to remind covered entities and business associates that “the protections of the Privacy Rule are not set aside during an emergency.” The...more

Privacy Tuesday – September 2014

Happy autumnal equinox Home Depot Breach – By the Numbers: - 56 million cards at risk (compare to Target = 40 million) - $62 million in estimated costs (compare to Target =$146 million and...more

Coming Fall 2014: HHS Launches Permanent Audit Program

Beginning in the Fall of 2014, a substantial number of covered entities and business associates will receive a notification and data request from the Health and Human Services' (HHS) Office for Civil Rights (OCR). According...more

Free HIPAA Help

Health care providers, health plans, business associates, and other entities affected by the federal HIPAA privacy and security regulations are quickly running out of excuses for not having a robust HIPAA compliance program...more

Hearing to Address HIPAA Accounting of Disclosures

The HHS Office of Civil Rights (OCR) announced that the Health Information Technology (HIT) Policy Committee’s Privacy and Security Tiger Team will hold a virtual, public hearing on Monday, September 30 from 11:45 a.m. to...more

Business Associate Definition Expanded and HHS Empowered to Impose New Civil Fines

Long-awaited omnibus regulations (Omnibus Rule) adopted earlier this year by the Department of Health and Human Services (HHS) Office for Civil Rights (OCR) made significant modifications impacting “business associates” to...more

Polsinelli Releases A HIPAA Business Associate Guide

In 2009, the Health Information Technology for Economic and Clinical Health Act ("HITECH") modified a number of provisions of the Health Insurance Portability and Accountability Act ("HIPAA") to strengthen HIPAA's privacy and...more

The HIPAA Omnibus Final Rule—Data Privacy and Security Implications for Business Associates and Covered Entities

On January 17, 2013, the Office for Civil Rights (‘‘OCR’’) of the U.S. Department of Health and Human Services (‘‘HHS’’) published the HIPAA Omnibus Final Rule (‘‘Final Rule’’) which OCR has trumpeted as carrying ‘‘the most...more

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