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Covered Entities Ransomware

Ankura

HIPAA Security Risk Analysis – How should regulated entities prepare for the Office for Civil Rights (OCR) Risk Analysis Audit...

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Following the Office for Civil Rights (OCR) recent publication of four settlements as part of a new Risk Analysis Audit Initiative. We explore the current regulatory language for Risk Analysis, the proposed language for Risk...more

Goodwin

Congress Considers New Cybersecurity Legislation Adjunct to HIPAA

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In the wake of Change Healthcare’s February 2024 ransomware attack, which affected the protected health information (PHI) of at least 100 million individuals — the largest breach of PHI in history — the federal government’s...more

BakerHostetler

It’s Officially Enforcement Season: OCR Announces First Penalty Under New Risk Analysis Initiative

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On October 31, 2024, the U.S. Department of Health and Human Services Office for Civil Rights (OCR) embraced the end of Spooky Season by announcing two more ransomware-related enforcement actions. ...more

Winstead PC

HIPAA Gets a Potential Counterpart in HISAA

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Americans hear about cybersecurity incidents on a frequent basis. As the adage goes, it is not a matter of “if” a breach or security hack occurs; it is a matter of “when.”...more

Holland & Knight LLP

Safeguarding Health Information: Takeaways from HHS and NIST 2024 HIPAA Security Conference

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President Ronald Reagan famously quipped, "I think you all know that I've always felt that the nine most terrifying words in the English language are: I'm from the Government, and I'm here to help."1 At an Oct. 23-24, 2024,...more

Health Care Compliance Association (HCCA)

2nd Settlement Triggered by 2017 Ransomware Attack Costs WA Practice $100K; ‘Not a Breach’

Let’s review for a moment. It’s not a HIPAA violation to be a victim of ransomware. It’s not a HIPAA violation to pay a ransom. It’s up to the covered entity (CE) to determine if a security or privacy incident is a...more

Holland & Knight LLP

Change Healthcare Cybersecurity Incident: Financial Impact and Resulting Litigation

Holland & Knight LLP on

On Feb. 21, 2024, the ransomware hacker group ALPHV, otherwise known as "BlackCat," disabled Change Healthcare's nationwide healthcare billing and information systems and demanded a ransom to unlock them....more

Bradley Arant Boult Cummings LLP

Mandatory Cybersecurity Incident Reporting: The Dawn of a New Era for Businesses

A significant shift in cybersecurity compliance is on the horizon, and businesses need to prepare. Starting in 2024, organizations will face new requirements to report cybersecurity incidents and ransomware payments to the...more

Tucker Arensberg, P.C.

Navigating HIPAA’s Breach Notification Rule Following A Breach

Tucker Arensberg, P.C. on

In light of the ongoing investigation of Change Healthcare’s ransomware attack that resulted in the improper disclosure of thousands of individuals’ PHI, now seems like a perfect time to discuss HIPAA’s requirements...more

Holland & Knight LLP

What HIPAA Security Rule Surprises Await Healthcare Providers for the Second Half of 2024?

Holland & Knight LLP on

The U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) has, as part of its mandate, the responsibility to enforce the Health Insurance Portability and Accountability Act (HIPAA) Security Rule....more

WilmerHale

8 Questions To Ask Before Final CISA Breach Reporting Rule

WilmerHale on

On April 4, the Cybersecurity and Infrastructure Security Agency published a notice of proposed rulemaking setting out mandatory reporting requirements for covered entities that experience cybersecurity incidents or make...more

Jones Day

CISA Releases Proposed Cyber Incident and Ransom Payment Reporting Rules to Implement CIRCIA

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CISA's proposed rules will require organizations operating in U.S. critical infrastructure sectors to report cyber incidents within 72 hours and ransom payments within 24 hours. ...more

Pillsbury Winthrop Shaw Pittman LLP

New CISA Rule Would Require Widespread Cyber Incident Reporting, Updated Timelines and Penalties for Critical Infrastructure...

Most businesses in the United States will have to file incident reports—including for ransomware payments—under the Proposed Rule. The Department of Homeland Security has the authority to issue subpoenas and even penalties...more

Schwabe, Williamson & Wyatt PC

Comments Sought on Proposed Requirements of the Cyber Incident Reporting for Critical ‎Infrastructure Act

On March 15, 2022, the Cyber Incident Reporting for Critical Infrastructure Act of 2022 was signed into law. Generally, CIRCIA requires “covered entities,” defined as entities in certain critical infrastructure sectors, to...more

Venable LLP

CIRCIA: Cyber Incident Reporting for Practically Everyone?

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A sweeping array of businesses are another step closer to requirements to report cybersecurity incidents and ransomware payments to the federal government. On April 4, 2024, the U.S. Department of Homeland Security's (DHS)...more

Constangy, Brooks, Smith & Prophete, LLP

CISA issues proposed regs on cyber incident reporting

Yesterday, March 27, the U.S. Cybersecurity and Infrastructure Security Agency published the Notice of Proposed Rulemaking under the Cyber Incident Reporting for Critical Infrastructure Act of 2022. It is important to note...more

Bricker Graydon LLP

HHS Issue Six Figure Penalty for Ransomware Attack

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Late last year, the Department of Health and Human Services (HHS) issued its first HIPAA settlement agreement involving a ransomware attack. In the press release announcing the settlement, HHS stated that they began...more

McGuireWoods LLP

Office for Civil Rights Settlement May Signal Increasing Scrutiny for Ransomware Attacks

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On Oct. 31, 2023, the U.S. Department of Health and Human Services’ Office for Civil Rights (OCR) announced it had settled with Doctors’ Management Services Inc. (DMS) over a self-reported ransomware attack that occurred in...more

Foley Hoag LLP - Security, Privacy and the...

Fintech Companies Prepare for Forthcoming Updates to the NY Cybersecurity Regulation

Proposed Amendments to 23 NYCRR Part 500 - If you are the chief information security officer (“CISO”) of a fintech company operating in New York, you may already be aware that, on November 9, 2022, the New York State...more

BakerHostetler

NYDFS Proposed Amendments to Its Cybersecurity Rules

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​​​​​​​On July 29, the New York Department of Financial Services (NYDFS) released Draft Amendments to its Part 500 Cybersecurity Rules that include a number of significant amendments to the rules, including notification...more

BCLP

Cyber Incident Reporting for Critical Infrastructure Act - What Companies Need to Know Now

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The Cyber Incident Reporting for Critical Infrastructure Act (“CIRCIA” or “the Act”) is a new federal law, adopted in March 2022, which requires critical infrastructure entities to report certain cybersecurity incidents and...more

BakerHostetler

Sounding the Alarm: New Federal Law Will Mandate the Reporting of Cybersecurity Incidents Involving Critical Infrastructure - What...

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In response to increased and persistent cybersecurity threats to American infrastructure, Congress passed the Strengthening American Cybersecurity Act (SACA), which President Joe Biden signed into law on March 15. SACA is...more

Alston & Bird

New Cybersecurity Law Will Require Cyber-Incident Reporting for Critical Infrastructure

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On March 1, the Senate unanimously passed the Strengthening American Cybersecurity Act of 2022, which will require critical infrastructure companies to report significant cyber-incidents and all ransom payments to the...more

Foster Garvey PC

New Reporting Requirements for Critical Infrastructure and Businesses

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The Cyber Incident Reporting for Critical Infrastructure Act of 2022 ("the Act") was signed into law by the President on March 15, 2022, as part of the Consolidated Appropriations Act. The purpose of the Act is to educate...more

NAVEX

Strengthening American Cybersecurity Act of 2022

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On March 1st, the United States Senate passed a historic cybersecurity bill with bipartisan and unanimous support. This bill impacts operators of federal infrastructure and federal civilian agencies. The Strengthening...more

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