The HIPAA Final Rule has been in effect since 2013, but HIPAA settlements following breaches continue to be reported. If you think the need for a risk analysis under HIPAA is not important, think again! On December 14, 2015, the Department of Health and Human Services (HHS) announced another $750,000 HIPAA settlement with the University of Washington Medicine (UWM). This settlement not only involves a payment of $750,000 but also requires a corrective action plan and annual reports to the Office for Civil Rights (OCR) on UWM’s compliance efforts. The settlement follows an OCR investigation after UWM reported a breach of electronic protected health information (ePHI) involving approximately 90,000 individuals after an employee downloaded an email attachment containing malicious malware. As a result, UWM’s IT system involving 76,000 patients names, medical record numbers, dates of service, and/or charges or bill balances as well as approximately 15,000 patients’ names, medical record numbers, and other demographics were compromised.
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