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What Does OCR’s Lowering of Maximum Annual Caps Mean for Covered Entities?

What Does OCR’s Lowering of Maximum Annual Caps Mean for Covered Entities?

The Office for Civil Rights (OCR) gave notice in the Federal Register that it is lowering the maximum annual caps for all HIPAA culpability tiers, except for the willful neglect without timely correction tier. There has been uncertainty for some time as to whether OCR’s interpretation of the statute was appropriate with regard to the $1.5M annual limit for all culpability levels.
Cyber and Privacy Risks Are Bleeding Over into Medical Professional Liability Risks | Update from the Cayman Captive Forum

Cyber and Privacy Risks Are Bleeding Over into Medical Professional Liability Risks | Update from the Cayman Captive Forum

Over November 27th to 29th, the 26th annual Cayman Captive Forum was held in Grand Cayman.  Over 1,400 specialists including captive directors, CFOs, CROs, service providers and captive managers from around the world met to discuss the issues most pressing to the captive insurance industry.  One of the key topics discussed was the apparent evolution from what started out as “HIPAA compliance risk” to “cybersecurity risk” to a “patient safety risk” and now “medical professional liability risk”.
Protecting Investments: Why Healthcare Private Equity Investors Must Increase Focus on Cybersecurity Risk

Protecting Investments: Why Healthcare Private Equity Investors Must Increase Focus on Cybersecurity Risk

Private equity investments in the healthcare industry have been increasing dramatically. In the past three years ...
Anthem Breach Learnings: HITRUST Certification Is Not A Replacement for An Enterprise Security Risk Analysis

Anthem Breach Learnings: HITRUST Certification Is Not A Replacement for An Enterprise Security Risk Analysis

The recent $16 million HIPAA settlement with Anthem, Inc. in the wake of the 2015 breach of nearly 79 million ...
Medical Device Security and CIO Insomnia

Medical Device Security and CIO Insomnia

During a conversation over drinks with a number of CIOs at a recent healthcare conference, I discovered that the ...
Panaceas, Shiny Objects and the Importance of Managing Risk in a Healthcare Environment–Part 3

Panaceas, Shiny Objects and the Importance of Managing Risk in a Healthcare Environment–Part 3

Is there a more challenging position anywhere in information security than that of a healthcare organization’s ...
Strengthening Your Cybersecurity Ecosystem — One Step at a Time

Strengthening Your Cybersecurity Ecosystem — One Step at a Time

Every day, it seems, cyber criminals figure out new ways to attack hospitals and compromise patient data and ...
Panaceas, Shiny Objects and the Importance of Managing Risk in a Healthcare Environment – Part 2

Panaceas, Shiny Objects and the Importance of Managing Risk in a Healthcare Environment – Part 2

Healthcare CIOs, CISOs, and other information risk management leaders face daunting challenges when it comes to ...
Panaceas, Shiny Objects and the Importance of Managing Risk in a Healthcare Environment–Part 1

Panaceas, Shiny Objects and the Importance of Managing Risk in a Healthcare Environment–Part 1

You’re the CISO of a healthcare organization and you just sat through an amazing sales presentation by one of your ...
HIPAA Risk Analysis Tip – #WannaStopCrying

HIPAA Risk Analysis Tip – #WannaStopCrying

Unless you've just returned from a 10-day interplanetary space mission, you've heard about the weaponization of ...
HIPAA Risk Analysis Tip – What Captures OCR’s Attention?

HIPAA Risk Analysis Tip – What Captures OCR’s Attention?

here’s pain in the voices of CISOs who haven’t been able to persuade their executive team to invest in an ...

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