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HHS Publishes ‘Voluntary’ Healthcare Cybersecurity Performance Goals in Record Time but Leaves Questions Unanswered

As previously reported in this blog, on Dec. 6, 2023, the Department of Health and Human Services (HHS or the Department) released a “concept paper,” which laid out its vision of future action regarding healthcare...more

HHS ‘Concept Paper’ Forecasts Stormy Cybersecurity Compliance Weather: New Cybersecurity Requirements and Increased Enforcement to...

On Dec. 6, the Department of Health and Human Services (HHS or the Department) released what it is calling a “concept paper” on its role in cybersecurity for the healthcare sector (the HHS paper). The HHS paper is sweeping in...more

OCR releases YouTube Addressing “Recognized Security Practices” in HIPAA Enforcement Context

As a Halloween treat for HIPAA-covered entities and business associates, on October 31, the Department of Health and Human Services Office for Civil Rights (OCR) released a new video on its YouTube channel, in which senior...more

‘Unboxing’ the New NIST Guidance: NIST Publishes Significant Update to Healthcare Cybersecurity Guide

​​​​​​​Without question, healthcare providers and the companies that support them operate in an elevated cybersecurity risk environment. And when a cybersecurity incident occurs, the ensuing regulatory inquiries and/or...more

Federal Banking Regulators Issue 36-Hour Computer-Security Incident Notification Requirement

As the federal government continues its whole-of-government response to cyber incidents, federal banking regulators took action to impose a new notice requirement on federally regulated banks. In November, the Federal Deposit...more

SEC Cybersecurity Actions Against Registered Firms for Business Email Compromises Emphasize Importance of MFA

On August 30, 2021, the Securities and Exchange Commission (“SEC”) announced three settled orders against several investment advisers, broker-dealers, and dual registrants for violations of Regulation S-P allegedly resulting...more

Pairing Real-World™ Problems with Realistic Solutions – a Push for Practical Information Governance

For those attorneys and information governance practitioners unfamiliar with recent pedagogic advancements, “real-world problem solving” moves teaching approaches away from the classical model that assumes individuals will...more

A Risk-Based Approach to the SolarWinds Vulnerability Disclosures

On December 13, 2020, SolarWinds disclosed that an unknown attacker compromised its network and inserted malicious code (referred to as the Sunburst vulnerability) into software updates for the Orion platform. In what will...more

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