News & Analysis as of

Office of Civil Rights Risk Management

Robinson+Cole Data Privacy + Security Insider

PIH Health Settles HIPAA Violations for $600,000

PIH Health, a health care entity located in California, suffered a data breach in June 2019 when 45 employee email accounts were compromised in a targeted phishing campaign. The accounts contained the protected health...more

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

Arnall Golden Gregory LLP

OCR Announces Fifth Settlement Under Its Risk Analysis Initiative

Background - On March 21, 2025, the U.S. Department of Health and Human Services, Office for Civil Rights (“OCR”) announced a settlement with Health Fitness Corporation (“Health Fitness”), a company that provides wellness...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

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

HHS OCR Settles HIPAA Security Rule Investigation with Health Fitness Corporation

On March 21, 2025, the U.S. Department of Health and Human Services’ Office for Civil Rights (OCR) announced a settlement of HIPAA security rule claims involving Health Fitness Corporation (Health Fitness). Health Fitness...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

Fox Rothschild LLP

Smart Considerations for the Use of Smart Glasses at Work

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As wearable technology continues to evolve, smart glasses are becoming an increasingly popular accessory. While these devices offer numerous benefits, they also present unique legal challenges, particularly in California,...more

Robinson+Cole Data Privacy + Security Insider

Warby Parker Settles Data Breach Case with OCR for $1.5M

Eyeglass manufacturer and retailer Warby Parker recently settled a 2018 data breach investigation by the Office for Civil Rights (OCR) for $1.5 million. According to OCR’s press release, Warby Parker self-reported that...more

Epstein Becker & Green

Proposed HIPAA Security Rule Updates May Significantly Impact Covered Entities and Business Associates

As we noted in our previous blog here, 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) proposing substantial revisions...more

Shook, Hardy & Bacon L.L.P.

OCR Enforcement Activity: Trends and Insights From a Limited Sample

Arecent report put the odds of an asteroid hitting the earth in December 2032 at 3.1%—which is 3,100 times more likely than an organization resolving an enforcement action with the U.S. Department of Health and Human...more

Saul Ewing LLP

Seeing is Believing: A Civil Money Penalty With Warby Parker Following Cybersecurity Incident

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On February 20, 2025, the U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR) announced a $1.5 million civil money penalty (CMP) against Warby Parker, Inc. (WP). WP is a manufacturer and online...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

Dentons

Ep. 47 – Make Your HIPAA Security Program Dynamic

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“Almost every stage of modern healthcare relies on stable and secure computer and network technologies.” The above is a direct quote from the Office of Civil Rights for Health & Human Services (“OCR”) in its proposed...more

Orrick, Herrington & Sutcliffe LLP

Proposed HIPAA Security Rule Update: What It Means for Cybersecurity in Health Care

Recently, the Department of Health and Human Services’ Office for Civil Rights (OCR) issued a notice of proposed rulemaking (NPRM) to update the Health Insurance Portability and Accountability Act (HIPAA) Security Rule—the...more

Baker Donelson

OCR Issues "Dear Colleagues" Letter Regarding AI in Medicine

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On May 6, 2024, OCR published the final rule interpreting and implementing Section 1557 at 45 C.F.R. § 92 (the Final Rule). The Final Rule regulates the use of patient care decision support tools, including AI algorithms for...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

Hogan Lovells

Slew of OCR activity underscores agency’s focus on security and AI

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Recent enforcement actions, audit activity, proposed rulemakings, and guidance issued by the U.S. Department of Health and Human Services (“HHS”), Office for Civil Rights (“OCR”) highlight the agency’s focus on health data...more

Epstein Becker & Green

Recent Developments in Health Care Cybersecurity and Oversight: 2024 Wrap Up and 2025 Outlook

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As Cyberattacks targeting the health care sector have continued to intensify over the past year, including ransomware attacks that have resulted in major data breaches impacting health care organizations, the protection of...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

Foley & Lardner LLP

New Artificial Intelligence (AI) Regulations and Potential Fiduciary Implications

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Fiduciaries should be aware of recent developments involving AI, including emerging and recent state law changes, increased state and federal government interest in regulating AI, and the role of AI in ERISA litigation. While...more

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