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For entities that are required to comply with HIPAA, staying abreast of recent HIPAA developments is an essential risk management strategy. Given the complexity of the HIPAA regulations, the fast pace of technology development, and the austere ramifications of a violation, it may be difficult to decide how to best allocate compliance resources. Taking stock of recent and upcoming enforcement activity can help organizations prioritize.

OCR Enforcement Actions

Over the last several years, the Department of Health and Human Services Office for Civil Rights (“OCR”) has steadily become more aggressive pursuing settlements and extracting higher settlement fines. This year in particular is shaping up to be OCR’s most vigorous enforcement year to date. In the first four months of 2016, OCR has already entered into six settlement agreements to resolve alleged HIPAA violations – the same number of settlements it entered into for all of 2015.

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