On November 8, 2011, the U.S. Department of Health and Human Services’ Office for Civil Rights (OCR) published on its website the details of its pilot program to perform up to 150 audits of compliance with the privacy, security and breach notification standards (collectively, the Standards) adopted under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health Act (HITECH Act) between November 2011 and December