[authors: M. Leeann Habte, Peter F. McLaughlin, R. Michael Scarano Jr.]
On March 13, 2012, the Office for Civil Rights (OCR) carried out its first enforcement action resulting from a breach report required by the Health Information Technology for Economic and Clinical Health (HITECH) Act. Blue Cross Blue Shield of Tennessee (BCBST) entered into a Resolution Agreement (Agreement) in which it agreed to pay $1.5 million and enter into a Corrective Action Plan (CAP) to address its Health Insurance Portability and Accountability Act (HIPAA) compliance program. In announcing the Agreement with BCBST, OCR Director Leon Rodriguez stated that the enforcement action sends an important message that OCR expects carefully designed, delivered, and monitored HIPAA compliance programs.