News & Analysis as of

Enforcement Actions Covered Entities

Hudson Cook, LLP

CFPB Enforcement Order Registry Requirements Effective September 16

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Who's Covered: Registrations and Written Statements - Generally, a covered nonbank with a covered order in effect on or after September 16, 2024, must register and submit information to the CFPB about the entity and the...more

Sheppard Mullin Richter & Hampton LLP

CFPB Final Rule Establishes Registry for Violators of Consumer Finance Laws

On June 3, the CFPB issued its final rule codifying its “repeat offender registry.” The registry will require certain nonbank entities subject to agency or court orders issued in connection with the provision of a consumer...more

Seward & Kissel LLP

SEC Adopts Data Privacy Rule Amendments to Regulation S-P

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Who may be interested: Investment Companies; Investment Advisers; Broker-Dealers; Transfer Agents - The SEC adopted amendments to Regulation S-P imposing new data privacy and security requirements on broker-dealers,...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

ArentFox Schiff

Key Takeaways from OCR’s CY22 HIPAA Reports to Congress

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On February 14, the US Department of Health and Human Services (HHS) Office for Civil Rights (OCR) issued its annual reports to Congress detailing its actions to enforce the privacy, security, and breach notification...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

BakerHostetler

HHS OCR Provides Annual Report to Congress Detailing 2022 Enforcement Activities

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On Feb. 16, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) published its 2022 Annual Report to Congress. ...more

Lathrop GPM

HIPAA Violations: What Providers Should Learn From the Failures of Others

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The federal agency responsible for enforcing the Health Insurance Portability and Accountability Act of 1996 (HIPAA) – the Office of Civil Rights (OCR) at the U.S. Department of Health and Human Services – recently submitted...more

BakerHostetler

HHS OCR Announces Largest Civil Monetary Penalty Imposed Since 2021 for Snooping Incident

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Nearly two months after settlement was reached, the Department of Health and Human Services Office for Civil Rights (HHS OCR) announced on Feb. 6 that it obtained a resolution agreement with Montefiore Medical Center over...more

Health Care Compliance Association (HCCA)

[Event] Healthcare Privacy Compliance Academy - May 6th - 9th, San Antonio, TX

Ideal for professionals with some compliance knowledge and experience, HCCA’s Healthcare Privacy Compliance Academy offers practitioners a deeper understanding of effective compliance management in a healthcare setting. The...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

Dorsey & Whitney LLP

HIPAA on the Horizon in the New Year: Important Lessons from an Active 2023 and Regulatory Initiatives to Watch for in 2024

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2023 marked 20 years since the first compliance deadline under the Health Insurance Portability and Accountability Act’s (“HIPAA”) privacy rule. Despite the two decades of experience with HIPAA, compliance continues to remain...more

McDermott Will & Emery

What Makes a Patient a “Patient”? Court Rejects Restrictive 340B Definition

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On November 3, 2023, the US District Court for the District of South Carolina issued a landmark order in Genesis Health Care, Inc. v. Becerra, a case analyzing the definition of a “patient” under the 340B Program Statute. The...more

McDermott Will & Emery

NYDFS Finalizes Amendments to Cybersecurity Regulation Impacting Financial Services Companies

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On November 1, 2023, the New York Department of Financial Services (NYDFS) amended Part 500, the cybersecurity regulation. These updates follow numerous NYDFS enforcement actions and other new cybersecurity rules, such as the...more

BakerHostetler

OCR’s October Initiatives: Strengthening Telehealth Security and HIPAA Compliance

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October has been a busy month for the OCR, which is tasked with enforcing the regulations issued under HIPAA. In the past week, the OCR released two new guidance documents aimed at reducing the privacy and security risks...more

Health Care Compliance Association (HCCA)

[Event] Healthcare Privacy Compliance Academy - October 16th - 19th, San Francisco, CA

Designed for professionals with some compliance knowledge and experience, HCCA’s Healthcare Privacy Compliance Academy is ideal for practitioners who want a deeper understanding of effective compliance management in a...more

Health Care Compliance Association (HCCA)

[Event] 2023 Healthcare Enforcement Compliance Conference - November 5th - 7th, Washington, DC

Hear directly from the enforcement community - Want to gain insight into properly monitoring, detecting, investigating, and managing violations? Join us at HCCA’s Annual Healthcare Enforcement Compliance Conference to...more

Sheppard Mullin Richter & Hampton LLP

State Comprehensive Privacy Laws – Beaver State Makes a Dozen

Oregon’s governor has now signed into law the state’s comprehensive privacy law. Meaning, there are now 12 states with these laws, six of which were passed just this year (others passed in 2023 were Iowa, Indiana, Tennessee,...more

Bass, Berry & Sims PLC

Florida Added to Growing List of New Comprehensive Consumer Privacy Laws

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On June 6, Florida Governor Ron DeSantis approved the passage of Senate Bill 262, which establishes the Florida Digital Bill of Rights (FDBR), set to go into effect July 1, 2024. Florida is now the tenth state to pass...more

Orrick, Herrington & Sutcliffe LLP

Top 5 Takeaways from NYDFS $1.2 Million Fine in Cybersecurity Case

On May 1, the New York Department of Financial Services (“NYDFS” or “Department”) and a trading platform entered into a consent order to resolve deficiencies identified during examinations conducted in 2018 and 2020. The...more

Dorsey & Whitney LLP

HHS OCR Settles HIPAA Investigation with Business Associate for $350,000

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Over the past decade, the number of health care data breaches reported to the U.S. Department of Health and Human Services’ Office for Civil Rights (“OCR”) has increased dramatically. From 2009 to 2022, over 5,000 data...more

Health Care Compliance Association (HCCA)

[Event] Regional Healthcare Compliance Conference - January 27th, Lake Buena Vista, FL

Looking for compliance education and networking in your area? HCCA’s Regional Healthcare Compliance Conferences offer practitioners convenient, local compliance education, including updates on the latest news in regulatory...more

Ankura

HIPAA Right of Access From a Dental Practice Perspective

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The Right of Access Initiative by the Office for Civil Rights (OCR) at the Department of Health and Human Services (HHS) began in 2019. On September 20, 2022, the OCR published its latest press release on the matter...more

Health Care Compliance Association (HCCA)

OCR Announces Trio of Access Cases; Already Stung, One Dental Chain Eliminates All Fees

Report on Patient Privacy 22, no. 10 (October, 2022) - How about free? Patients daily face the machinations of getting records from their providers, and health care practices, hospitals and even dentists struggle with...more

Saul Ewing LLP

Keep Your PHI Out of the Trash! OCR Announces Large Settlement With a Medical Practice After PHI Found in a Dumpster

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On August 23, 2022, the Office for Civil Rights (OCR) within the U.S. Department of Health and Human Services (HHS) announced a $300,640 settlement and a Corrective Action Plan (“CAP”) with New England Dermatology P.C., d/b/a...more

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