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Office of Civil Rights Data Breach Civil Monetary Penalty

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

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

Jackson Lewis P.C.

Florida Healthcare Provider Faces $1.19M HIPAA Penalty Following Independent Contractor Breach

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A healthcare provider delivering pain management services in Florida and other states faces a $1.19 million civil monetary penalty from the U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR)....more

Health Care Compliance Association (HCCA)

Privacy Briefs: May 2024

Kaiser Permanente is notifying 13.4 million current and former members that their personal information may have been compromised when it was transmitted to tech giants Google, Microsoft Bing and X (formerly Twitter) when...more

Holland & Hart LLP

Business Associate Agreements: Requirements and Suggestions

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The HIPAA Privacy and Security Rules generally require covered entities (including most healthcare providers) to execute written agreements (“business associate agreements” or “BAAs”) with their business associates before...more

ArentFox Schiff

Key Takeaways from OCR’s Latest Annual HIPAA Reports to Congress

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On February 17, 2023, the US Department of Health and Human Services Office for Civil Rights (OCR) released two companion reports to Congress detailing its actions in 2021 to enforce the privacy, security, and breach...more

Health Care Compliance Association (HCCA)

Report on Patient Privacy Volume 22, Number 11. MD Anderson Won Against OCR, But Agency’s Response—Including on Fines—Keeps...

Report on Patient Privacy Volume 22, Number 11. (November 2022) Nearly five years passed from the time the University of Texas MD Anderson Cancer Center reported to the HHS Office for Civil Rights (OCR) that three...more

Health Care Compliance Association (HCCA)

OCR: Current Fines Too Low to Spur Compliance; Agency Also Seeks Funding Boost, Injunctive Relief

Report on Patient Privacy 22, no. 5 (May, 2022) - Compared to other agencies, the HHS Office for Civil Rights (OCR) is a little fish in the big federal pond, but it has an outsize effect on HIPAA covered entities (CEs) and...more

Faegre Drinker Biddle & Reath LLP

Fifth Circuit Decision Motivates Covered Entities to Appeal Unreasonable Enforcement Outcomes

The United States Court of Appeals for the Fifth Circuit (the “Court”) vacated a $4,348,000 civil monetary penalty (“CMP”) imposed by the U.S. Department of Health and Human Services’ Office for Civil Rights (“HHS-OCR”) in...more

Hogan Lovells

Fifth Circuit Vacates $4.3M Penalty Against MD Anderson Related to Data Losses

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There has been a significant development in the ongoing debate regarding the scope of the authority of the Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) to issue penalties under the Health...more

Rivkin Radler LLP

New Haven Settles HIPAA Breach For $202K

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The city of New Haven, Connecticut recently agreed to pay $202,400 to the U.S. Department of Health and Human Services’ Office for Civil Rights (OCR) to settle multiple HIPAA violations in connection with a 2016 incident at...more

Health Care Compliance Association (HCCA)

Small N.C. Health Center Pays Price for 2011 Breach, Noncompliance; 'We Had to Move On'

Report on Patient Privacy 20, no. 8 (August 2020)  - Last month, leaders from Agape Health Services in rural Washington, North Carolina, were happy to share photos of the shell of a building in neighboring Plymouth, that,...more

Ballard Spahr LLP

HIPAA 2019 Year in Review: OCR’s Enforcement of HIPAA Security Rule

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Although the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) may yet announce one or two year-end settlements, it appears that 2019 will be known more for the implementation of changes in...more

Mintz - Privacy & Cybersecurity Viewpoints

A New Decade of HIPAA – What Can We Expect?

As the decade winds down, it’s hard to believe that the HIPAA Privacy and Security Rules are almost twenty years old. It has been ten years since the U.S. Department of Health and Human Services (HHS) Office for Civil Rights...more

Health Care Compliance Association (HCCA)

As MD Anderson Keeps Up Its Legal Fight, U. Rochester Pays OCR $3M

Report on Research Compliance 17, no. 1 (January 2020) - Ah, those pesky residents. If you’re a teaching hospital, you can’t live without them, right? But sometimes living with them is mighty costly, as the University of...more

Health Care Compliance Association (HCCA)

'Misinterpretation' of Breach Rule, Lack of Internal BAA Cost Hospital Group $2.1M

Report on Patient Privacy 19, no. 12 (December 2019) - Sentara Hospitals, a nonprofit group of 12 medical centers in Virginia and North Carolina, will implement a fairly minimal two-year corrective action plan (CAP) and...more

Faegre Drinker Biddle & Reath LLP

$1.6 Million Civil Money Penalty for HIPAA Breach Impacting 6,617 Individuals

The Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services imposed a $1.6 million civil money penalty (CMP) against the Texas Health and Human Services Commission, Department of Aging and Disability...more

Ballard Spahr LLP

OCR Hits Health System with $2.2M Fine for HIPAA Violations

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The U.S. Department of Health and Human Services Office of Civil Rights (OCR) imposed $2,154,000 in civil monetary penalties against Jackson Health System in Florida for failing to meet HIPAA privacy and security...more

Akerman LLP - Health Law Rx

Caution: Curb Your Enthusiasm for the Reduced HIPAA Annual Limits

Until recently, the annual limit for civil monetary penalties (CMP) that could be levied against covered entities and business associates in violation of the Health Insurance Portability and Accountability Act of 1996, as...more

Polsinelli

HHS’s Enforcement Discretion Notice May Signal More Potential Violations

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The HHS Office for Civil Rights (“OCR”) issued a notice in the Federal Register regarding its Enforcement Discretion (84 Fed. Reg. 18151) on April 30, 2019. HHS announced that HHS will now apply a different cumulative annual...more

Ballard Spahr LLP

HHS Decreases Maximum HIPAA Penalties

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The Department of Health and Human Services has announced that it is lowering the maximum amount it will assess for most types of HIPAA violations. Although the change is couched as an exercise of discretion, HHS states that...more

Mintz - Health Care Viewpoints

Physician's Response to a Public Patient Complaint Leads to Penalty under HIPAA

The U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR) recently announced a no-fault settlement, including a $125,000 penalty and a two year corrective action plan for Allergy Associates of...more

Sheppard Mullin Richter & Hampton LLP

Are You a “Hybrid Entity” under the Health Insurance Portability and Accountability Act of 1996? The $4,348,000 Question

A single, multidisciplinary entity, like a university, may include certain departments that use PHI, and other departments that do not. Such institutions are eligible to (and should) self-identify as “hybrid entities” to...more

Bradley Arant Boult Cummings LLP

Summary Judgment: Recent HIPAA Case Emphasizes Encryption, Action on Risk Analysis - AHLA Health Information and Technology...

On June 18, 2018, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced that an HHS Administrative Law Judge (“ALJ”) granted summary judgment to OCR in an enforcement action...more

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