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ARTICLE · 19 MAY 2014

HHS OCR Settles Post-Data Breach Investigation For Record $4.8M

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HHS OCR announced a pair of resolution agreements with New York Presbyterian Hospital (NYP) and Columbia University (CU) totaling $4.8 million dollars.

United StatesPrivacy

On May 7, 2014, HHS OCR announced a pair of resolution agreements with New York Presbyterian Hospital (NYP) and Columbia University (CU) totaling $4.8 million dollars—the highest settlement amount to date.  These resolution agreements make it clear that organizations must be able to propose steps to analyze security risks for ePHI as specified by HIPAA and plan strategies to manage identified risks.

Pursuant to 45 C.F.R. §§ 164.308(a)(1)(i)(ii)(A) and (B), an organization must conduct an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of EPHI and implement security measures sufficient to reduce risks and vulnerabilities to a reasonable and appropriate level to:

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