HIPAA

And here we are with a just-announced $5.1m negotiated penalty (Excellus health plans) based on a breach affecting 9.3m patient records, exposed over an 18-month period. The overall takeaway, at bottom, is not that profound ... just: take this stuff ...

"Arbitrary and capricious" is the legal standard for overturning an administrative agency final decision. Interestingly, OCR ratcheted back its maximum penalties figures between the time this fine was first assessed and present. We'll see if that approach ...

Thank you for the link

Thank you Frank!!

Apologies for previous wrong month, system wouldn't let me change subj line. https://www.federalregister.gov/d/2020-27157 Regards, Theresa Defino Editor Report on Research Compliance ...