By Erin Fleming Dunlap, Dmitry Shifrin, and Ken Briggs
On Monday, April 27, 2015, the Department of Health and Human Services ("HHS"), Office for Civil Rights ("OCR") announced a settlement with Cornell Prescription Pharmacy ("Cornell"). Under the Resolution Agreement, Cornell agreed to pay HHS $125,000 and adopt a Corrective Action Plan ("CAP") to address the deficiencies in its HIPAA compliance program.
Significantly, the $125,000 settlement does not take into account the time, labor and most likely legal fees that were required to navigate through the investigation or will be required to comply with the CAP. There is no question that proactively implementing, maintaining and training on measures to protect patient information ultimately reduces costs and limits exposure to government enforcement and the quick-rising tide of state court lawsuits targeting data breaches.
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