Lexology October 25, 2023
Many HIPAA covered entities and business associates struggle with developing and implementing a sanctions policy. What should it say, is zero-tolerance required, do we have to impose discipline in every case, etc. These are examples of frequent and thorny questions that arise in connection with the development and implementation of these policies. But they are important questions to answer, especially considering the federal Office for Civil Rights (OCR) position concerning these policies.
The healthcare industry continues to sit at or near the top of lists of industries affected by data breaches, whether caused by cyber criminals or self-inflicted wounds. These data breaches can take many forms – ransomware, social engineering, snooping, misdirected patient data, responding to patient complaints, tracking technologies,...
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