One of the most common questions I get is whether a particular disclosure constitutes a breach that requires notification to the individual and completing a breach notification report with the
On November 6, 2020 the Office for Civil Rights issued a press release announcing the settlement of its Tenth investigation under the Right to Access Initiative. I have written about
In June 2019, when the Criminal Division of the Department of Justice, (DOJ), updated its guidance document on how prosecutors are to evaluate an organization’s compliance program, (Evaluation of Corporate
As I write this blog post I am watching the crew working on the road in front of my office. It has been a long 5 months, yes COVID has
Most every compliance program has a document called the Code of Conduct, Code of Ethics or some other title that indicates the organization’s “commitment” to doing the right thing. Typically
On September 21, 2020, the Office for Civil Rights (OCR) issued a press release announcing a $1.5 million settlement with Athens Orthopedic Clinic. The basis for the breach report that
There is no way to deny the fact life seems to move faster each and every year. New and exciting technology allows us to cut the amount of time it
Michael Gerber wrote a book about being an entrepreneur called “The E Myth” in which he emphasized the importance of working “on” the business and not just “in” the business.
In the last week the Office for Civil Right (OCR) has issued press releases on two enforcement actions which involve very different types of providers but send a consistent message
At some point in time every organization will face a search warrant, receive a subpoena for records, or a request from a law enforcement official for copies of medical records.
I recently wrote a newsletter article on the importance of walking through the organization with “HIPAA Goggles” on as a way to see potential HIPAA issues that may be overlooked
On April 15, 2020 the Office of Inspector General released the results of its audit of the South Carolina Medicaid fee-for-service telemedicine program. The results were staggering. The OIG determined