$31,000 is a High Price to Pay for Failure to Implement a Business Associate Agreement

April 28, 2017. On April 14, 2017—the Effective Date—the Office for Civil Rights (OCR) of the U.S. Department of Health and Human Services (HHS) settled with Center for Children’s Digestive Health (CCDH), “a small, for-profit health care provider that operates a pediatric subspecialty practice in seven clinic locations across Illinois,” for “impermissibly [disclosing] the [protected health information] of at least 10,728 individuals” to a “third-party vendor that stored inactive paper medical records” “without obtaining [the vendor’s] satisfactory assurances, in the form of a written business associate agreement, [that the vendor] would appropriately safeguard the PHI.

CFO Magazine Highlights Cost of Safeguards in Article on McKinsey Research: The Rising Strategic Risks of Cyber Attacks

Earlier this month, we commended your attention to the referenced McKinsey Research, which CFO Magazine has picked up in its online May 16, 2014, weekly briefing at http://ww2.cfo.com.  I revisit the McKinsey Research in this article because it has an important statement regarding the costs of security measures as stated in the Flexibility of Approach general requirements for complying with the HIPAA Security Rule at 45 CFR 164.306(b):

 

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