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ARTICLE · 20 AUGUST 2025

OCR's "Risk Analysis" Enforcement Initiative Continues Against Another Business Associate

Jackson Lewis P.C.
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On August 18, 2025, the Department of Health and Human Services' Office for Civil Rights (OCR) announced a settlement with BST & Co. CPAs, LLP (BST). The announcement continues OCR's escalating enforcement...

United StatesTechnology
Joseph J. Lazzarotti
Joseph J. Lazzarotti

On August 18, 2025, the Department of Health and Human Services' Office for Civil Rights (OCR) announced a settlement with BST & Co. CPAs, LLP (BST). The announcement continues OCR's escalating enforcement of the HIPAA Security Rule, particularly around ransomware and risk analysis inadequacies.

For the OCR, this is the agency's 15th ransomware enforcement action and 10th enforcement action in OCR's Risk Analysis Initiative. For BST, the settlement means the payment of a Resolution Amount of $175,000 and a two-year Corrective Action Plan.

What Happened?

The underlying facts outlined in the settlement are all too familiar. BST discovered a ransomware attack in December 2019 triggered by a phishing email. The business associate reported the attack to OCR in February 2020. The attack affected client PHI pertaining to 170,000 individuals.

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