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

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

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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

Epstein Becker & Green

Gender-Affirming Care Protections Eroded by Recent HHS Guidance and White House Executive Orders

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On February 20, 2025, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) announced the recission of “HHS Notice and Guidance on Gender Affirming Care, Civil Rights, and Patient Privacy” (the...more

Perkins Coie

HHS Proposal To Strengthen HIPAA Security Rule

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Earlier this year, the U.S. Department of Health and Human Services Office for Civil Rights (OCR) adopted a new proposal to strengthen the Health Insurance Portability and Accountability Act (HIPAA) security standards...more

Husch Blackwell LLP

HHS Rescinds 2022 Guidance on Anti-Discrimination and Privacy in Gender-Affirming Care

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On February 20, 2025, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) issued a letter rescinding with immediate effect its March 2022 “HHS Notice and Guidance on Gender Affirming Care,...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

ArentFox Schiff

Proposed Changes to the HIPAA Security Rule: What Regulated Entities Need to Know

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In the final days of the Biden Administration, the US Department of Health and Human Services (HHS) Office for Civil Rights (OCR) issued a notice of proposed rulemaking (NPRM) to modify the Security Rule under the Health...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

Vorys, Sater, Seymour and Pease LLP

Proposed Update to the HIPAA Security Rule

In early January, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) published a Notice of Proposed Rulemaking. The Proposed Rule would modify the Security Standards for the Protection of...more

Husch Blackwell LLP

Compliance with the HIPAA Privacy Rule to Support Reproductive Healthcare Privacy

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On April 22, 2024, the Health and Human Services’ Office for Civil Rights (OCR) issued the HIPAA Privacy Rule to Support Reproductive Health Care Privacy Final Rule. The final rule limits the sharing of protected health...more

Paul Hastings LLP

HHS OCR Releases Proposed Updates to HIPAA Security Rule

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On December 27, 2024, the U.S. Department of Health and Human Services (HHS), through the Office for Civil Rights (OCR), announced a Notice of Proposed Rulemaking (NPRM) to amend the Security Standards for the Protection of...more

Faegre Drinker Biddle & Reath LLP

Proposed HIPAA Security Rule Updates — Implications for Covered Entities and Their Information Security Programs

On January 6, 2025, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) published a notice of proposed rulemaking (Proposed Rule) updating the Health Insurance Portability and...more

McCarter & English, LLP

Season of Enforcement: OCR Announces Its Sixth Enforcement Action of 2025

With 2025 barely three weeks old, the US Department of Health and Human Services Office for Civil Rights (OCR) has already announced six enforcement actions for the new year. Particularly significant is the advancement of...more

Bass, Berry & Sims PLC

Proposed Rulemaking to Strengthen HIPAA Security Rule

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On January 6, the Department of Health and Human Services Office for Civil Rights (OCR) published a notice of proposed rulemaking (Proposed Rule) that would strengthen the requirements of the security rule promulgated...more

King & Spalding

OCR Proposes Updates to Strengthen the HIPAA Security Rule

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On December 27, 2024, the Office for Civil Rights (OCR) at HHS issued a Notice of Proposed Rulemaking (the Proposed Rule) intended to update the Security Rule under the Health Insurance Portability and Accountability Act...more

Bradley Arant Boult Cummings LLP

Introducing Bradley’s Series on HHS’s Proposed HIPAA Security Rule Updates

Bradley is launching a multipart blog series on the U.S. Department of Health and Human Services’ (HHS) proposed changes to strengthen cybersecurity protections for electronic protected health information (ePHI) regulated...more

Husch Blackwell LLP

OCR Announces Proposed Updates to HIPAA Security Rule, Raises the Bar for Healthcare Cybersecurity

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On December 27, 2024, the U.S. Department of Health and Human Services (HHS), through its Office for Civil Rights (OCR), issued proposed changes to the Health Insurance Portability and Accountability Act of 1996 (HIPAA)...more

McDermott Will & Emery

ASTP Adopts New Protecting Care Access Exception

McDermott Will & Emery on

On December 17, 2024, the US Department of Health and Human Services (HHS) Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP) published the Health Data,...more

Ballard Spahr LLP

HHS Proposes Significant Updates to HIPAA Security Rule

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On January 6, 2025, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) published a Notice of Proposed Rulemaking (“NPRM”) to amend the Health Insurance Portability and Accountability Act...more

Baker Donelson

Proposed HIPAA Security Rule Updates

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The Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) issued a Notice of Proposed Rulemaking (NPRM) on December 27, 2024, to update the Health Insurance Portability and Accountability Act...more

Whiteford

Client Alert: HIPAA Happenings: U.S. Department of Health and Human Services Proposes Updated HIPAA Cybersecurity Rules

Whiteford on

On January 6, 2025, the U.S. Department of Health and Human Services (“DHHS”) Office of Civil Rights (“OCR”) published a proposed rule entitled, “HIPAA Security Rule to Strengthen the Cybersecurity of Electronic Health...more

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