settlement

$1.55 million settlement underscores the importance of executing HIPAA business associate agreements$1,550,000

Resolution Mar 2016

Penalty

$1,550,000

Action type

Settlement

Entity profile

Case number

What went wrong

$1.55 million settlement underscores the importance of executing HIPAA business associate agreements - March 16, 2016

  • Navigate to: HIPAA for Professionals Regulatory Initiatives Privacy Summary of the Privacy Rule Guidance Combined Text of All Rules HIPAA Related Links Security Security Rule NPRM Summary of the Security Rule Security Guidance Cyber Security Guidance Breach Notification Breach Reporting Guidance Reports to Congress Regulation History Compliance & Enforcement Enforcement Rule Enforcement Process En

Full description

Navigate to: HIPAA for Professionals Regulatory Initiatives Privacy Summary of the Privacy Rule Guidance Combined Text of All Rules HIPAA Related Links Security Security Rule NPRM Summary of the Security Rule Security Guidance Cyber Security Guidance Breach Notification Breach Reporting Guidance Reports to Congress Regulation History Compliance & Enforcement Enforcement Rule Enforcement Process Enforcement Data Resolution Agreements Case Examples Audit Reports to Congress State Attorneys General Special Topics Parental Access Mental and Behavioral Health Change Healthcare Cybersecurity Incident FAQs HIPAA and COVID-19 HIPAA and Reproductive Health HIPAA and Final Rule Notice HIPAA and Telehealth HIPAA and FERPA Research Public Health Emergency Response Health Information Technology Health Apps Patient Safety Covered Entities & Business Associates Business Associate Contracts Business Associates Training & Resources FAQs for Professionals Other Administrative Simplification Rules Substance Use Disorder Confidentiality $1.55 million settlement underscores the importance of executing HIPAA business associate agreements North Memorial Health Care has agreed to settle charges that it potentially violated the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy and Security Rules by failing to implement a business associate agreement with a major contractor and failing to institute an organization-wide risk analysis to address risks and vulnerabilities to its patient information. North Memorial is a comprehensive, not-for-profit health care system in Minnesota that serves the Twin Cities and surrounding communities. The settlement includes a monetary payment of $1,550,000 and a robust corrective action plan. Read the Press Release Read the Resolution Agreement Content last reviewed March 16, 2016

Timeline

  • ResolutionMar 2016
  • Incident and investigation milestones are not consistently published by OCR in machine-readable form.

Key takeaways for your organization

  • Treat internet-facing systems and vendor-hosted environments as in-scope for HIPAA risk analysis and technical safeguards testing.
  • Maintain an actionable risk analysis tied to remediation milestones; evidence should map to Security Rule implementation specifications.
  • Align policies, procedures, and evidence with the specific CFR provisions cited in OCR resolutions affecting your entity type.
  • Run tabletop exercises for breach response, OCR inquiry handling, and privilege-preserving communications with counsel.

Related actions

Source

U.S. Department of Health and Human Services release

Source: U.S. Department of Health and Human Services, Office for Civil Rights. medcomply.ai aggregates public materials for educational use — not legal advice.