Tuesday, April 12, 2011

OCR Exercises Its Enforcement Discretion

Last month we had the first case in which Office of Civil Rights used it HIPAA civil money penalty power, and it is a douzy. 


See full article here.


Note to self #1: respond to subpoena from the OCR. 


Note to self #2: when responding to a HIPAA violation complaint, do not include PHI on 4,500 patients outside the scope of the complaint.