Lexology September 18, 2023
Paying the $1.3 million fine is the easy part. Complying with the CAP is a different undertaking.
On Sept. 11, 2023, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) announced an unprecedented resolution agreement and corrective action plan (“CAP”) with L.A. Care Health Plan to settle investigations over potential HIPAA violations.
As part of the resolution agreement, L.A. Care agreed to pay $1.3 million. That is the easy part—a minor endeavor compared to complying with the CAP. Attached to the resolution agreement as Appendix A, the CAP will keep the L.A. Care chief compliance officer, privacy officer and information security officer busy with the following tasks:
- Conducting an enterprise-wide risk analysis
- Developing and...
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