News & Analysis as of

Enforcement Actions Office of Civil Rights Department of Health and Human Services (HHS)

Health Care Compliance Association (HCCA)

From $5,000 to $800,000: Days Apart, OCR Security Settlements Show Puzzling Math

A single incident that may have started as a personal vendetta or an extortion threat seven years ago has cost a Florida health care system $800,000, and comes on the heels of an unrelated breach suffered by a different...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

2025 Enforcement Trends: Risk Analysis Failures at the Center of HHS’s Multimillion-Dollar HIPAA Penalties

In the first five months of 2025, the U.S. Department of Health and Human Services’ (HHS) Office for Civil Rights (OCR) announced it had entered into ten Health Insurance Portability and Accountability Act (HIPAA) resolution...more

Health Care Compliance Association (HCCA)

Former OCR Director Fontes Rainer Reflects On ‘Imperfect’ RSP Law, Urges Final Security Reg

In October, the HHS Office for Civil Rights (OCR) fined Providence Medical Institute (PMI) $240,000, an amount that reflected a 20% discount for having “recognized security practices” (RSPs) in place. But many more covered...more

Health Care Compliance Association (HCCA)

OCR Loses Staff, Faces Move to New ‘Enforcement’ Office; Will HIPAA Focus, Independence Suffer?

Today, the HHS Office for Civil Rights (OCR) stands shoulder-to-shoulder with the likes of the Office of Inspector General and Office of General Counsel, one of just a dozen or so agencies reporting directly to the secretary....more

Clark Hill PLC

Right To Know - April 2025, Vol. 28

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Welcome to your monthly rundown of all things cyber, privacy, and technology, where we highlight all the happenings you may have missed. ...more

Warner Norcross + Judd

OCR Enforcement Intensifies: Key Takeaways on Risk Analysis and Right of Access

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The Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services has renewed its focus on two critical areas of HIPAA compliance: risk analysis and individual right of access. These enforcement...more

Saul Ewing LLP

OCR Imposes $200,000 Civil Money Penalty Against HIPAA-Covered Entity

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On March 6, 2025, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced a civil money penalty (“CMP”) of $200,000 against Oregon Health & Science University (“OHSU”) for failing to...more

Jackson Lewis P.C.

Health Fitness, OCR’s Risk Analysis Initiative, and the ERISA Fiduciary Duty to Select Plan Service Providers

Jackson Lewis P.C. on

On Friday, the U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR) announced the fifth enforcement action under its Risk Analysis Initiative. In this case, OCR reached a settlement with Health...more

Proskauer on Privacy

Proskauer on Privacy: 2024 Reflections & 2025 Predictions

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2024 marked another significant year for privacy law, with new state legislation and high-stakes litigation reshaping the landscape. Legal battles over tracking technologies, biometric data, and children’s privacy...more

Nilan Johnson Lewis PA

Nine Steps Healthcare Entities Should Take to Prevent Cyberattacks

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The U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently imposed a $1.5 million civil money penalty against Warby Parker, Inc., a manufacturer and online retailer of eyewear, for...more

Health Care Compliance Association (HCCA)

We’ll Take the Fine: OCR’s ‘Unwarranted,’ Costly Demands Prompted Hospital’s $538K Payment

The saga that led Children’s Hospital Colorado to accept a fine of more than $500,000 imposed by the HHS Office for Civil Rights (OCR) began on July 11, 2017, when a physician’s email account containing details on 3,300...more

Saul Ewing LLP

Two CMPs and One Settlement Close Out 2024 HIPAA Enforcement

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December 2024 was an active month for the U.S. Department of Health and Human Services ("HHS"), Office for Civil Rights ("OCR"). OCR announced (i) a $1.19 million civil monetary penalty ("CMP") against Gulf Coast Pain...more

Quarles & Brady LLP

HHS Office for Civil Rights Reaffirms Interest in Enforcement Related to Reproductive Health Information

Quarles & Brady LLP on

On December 2, 2024, the U.S. Department of Health and Human Services Office for Civil Rights (HHS OCR) announced a settlement with Holy Redeemer Family Medicine, a Pennsylvania covered entity, regarding an alleged violation...more

Holland & Knight LLP

HIPAA Tidings: A Look at OCR's Recent Enforcement Actions

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In addition to holiday celebrations, the month of December typically ushers in a final round of enforcement actions by the U.S. Department of Health and Human Services' (HHS) Office of Civil Rights (OCR), and 2024 is no...more

Saul Ewing LLP

Emergency Medical Service Provider Agrees to Pay a $90,000 HIPAA Settlement Following Ransomware Attack

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On November 1, 2024, the U.S. Department of Health and Human Services (“HHS”), Office for Civil Rights (“OCR”) announced a $90,000 settlement with Bryan County Ambulance Authority (“BCAA”), a provider of emergency medical...more

BakerHostetler

DSIR Deeper Dive: Tracking the Crackdown on Tracking/Pixel Technologies: Web Litigation and Regulatory Landscape - Part 2

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In the first part of this blog post, we looked into the OCR and FTC’s focus on third-party tracking technologies. We also reviewed the AHA Lawsuit and its impact for the use of tracking technologies. In this blog post, we...more

BakerHostetler

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

BakerHostetler on

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

Health Care Compliance Association (HCCA)

Recognized Security Practices ‘Saved’ Covered Entity $60K of $300K Fine, But Which Ones Remain a Mystery

Covered entities (CEs) and business associates (BAs) may receive a “discount” for having recognized security practices (RSPs) in place when the HHS Office for Civil Rights (OCR) calculates financial penalties for Security...more

Saul Ewing LLP

No “Trick”: Plastic Surgery Practice Agrees to Pay a $500,000 HIPAA Settlement Following Ransomware Attack

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On October 31, 2024, the U.S. Department of Health and Human Services (“HHS”), Office of Civil Rights (“OCR”) announced a $500,000 settlement with Plastic Surgery Associates of South Dakota (“PSA”) concerning potential...more

Williams Mullen

Will 50 Enforcement Actions Be Sufficiently “Loud and Clear” that HIPAA’s Right of Access Must Be Honored?

Williams Mullen on

Because of pervasive misunderstanding of the Health Insurance Portability and Accountability Act (HIPAA), providers all too frequently create impermissible barriers to patient access to medical records. In many cases, such...more

Saul Ewing LLP

A “Scary” OCR CMP Imposed Upon a Solo Dental Practice

Saul Ewing LLP on

On October 21, 2024, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced a civil monetary penalty (“CMP”) of $70,000 against a solo dental practice that provides family dental...more

Williams Mullen

Ransomware Hat Trick: OCR Scores Three Major Enforcement Actions in 2024

Williams Mullen on

Ransomware attacks are a growing threat in the health care sector due to the value of personal health information (PHI). In addition to being expensive, these attacks can cripple health care operations, delay patient care,...more

Saul Ewing LLP

Medical Practice Ordered to Pay HIPAA Civil Monetary Penalty Following Acquisition

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In October 2024, the U.S. Department of Health and Human Services (“HHS”), Office for Civil Rights (“OCR”) announced the imposition of a civil monetary payment against Providence Medical Institute (“PMI”), a large medical...more

Baker Donelson

The Office for Civil Rights Recently Settled Two Ransomware Related Investigations

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The U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently settled two ransomware cases with covered entities. These cases signal the government's growing concern with health care...more

Saul Ewing LLP

Medical Practice Agrees to Pay $250,000 HIPAA Settlement Following Ransomware Attack

Saul Ewing LLP on

In late September 2024, the U.S. Department of Health and Human Services (“HHS”), Office for Civil Rights (“OCR”) announced a settlement with Cascade Eye and Skin Centers, P.C., a health care provider in the state of...more

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