Resolution Agreement with the University of California at Los Angeles Health System — Corrective action / RA
Resolution Jul 2011
Penalty
Corrective action / RA
Action type
Resolution agreement
Entity profile
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Case number
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What went wrong
Resolution Agreement with the University of California at Los Angeles Health System - July 6, 2011
- 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 Resolution Agreement UCLA Health System Settle Potential Violations of the HIPAA Privacy and Security RulesFollowing an investigation by the Department of Health and Human Services (HHS) Office for Civil Rights (OCR), the University of California at Los Angeles Health System (UCLAHS) has agreed to settle potential violations of the HIPAA Privacy and Security Rules for $865,500 and has committed to a corrective action plan aimed at remedying gaps in its compliance with the rules.The resolution agreement resolves two separate complaints filed with OCR on behalf of two celebrity patients who received care at UCLAHS. The complaints alleged that UCLAHS employees repeatedly and without permissible reason looked at the electronic protected health information of these patients.OCR’s investigation into the complaints revealed that from 2005-2008, unauthorized employees repeatedly looked at the electronic protected health information of numerous other UCLAHS patients. Through policies and procedures, entities covered under HIPAA must reasonably restrict access to patient information to only those employees with a valid reason to view the information and must sanction any employee who is found to have violated these policies.“Covered entities are responsible for the actions of their employees. This is why it is vital that trainings and meaningful policies and procedures, including audit trails, become part of the every day operations of any health care provider,” said OCR Director Georgina Verdugo. “Employees must clearly understand that casual review for personal interest of patients’ protected health information is unacceptable and against the law.”The corrective action plan requires UCLAHS to implement Privacy and Security policies and procedures approved by OCR, to conduct regular and robust trainings for all UCLAHS employees who use protected health information, to sanction offending employees, and to designate an independent monitor who will assess UCLAHS compliance with the plan over 3 years.“Covered entities need to realize that HIPAA privacy protections are real and OCR vigorously enforces those protections. Entities will be held accountable for employees who access protected health information to satisfy their own personal curiosity,” said Director Verdugo. Additional InformationRead the Resolution Agreement and CAPRead the HHS Press Release Content last reviewed June 7, 2017
Timeline
- ResolutionJul 2011
- 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.