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Enhanced Penalties and Stiffer Enforcement for HIPAA Violations
Verrill Dana LLP Link to more items from this source
[Guidance Overview]
Apr. 7, 2013

"Note that the penalties assessed against a covered entity or business associate may well exceed $1.5 million if multiple HIPAA requirements have been violated because each category of violation may be counted separately (in addition to counting multiple violations of the same provision). Importantly, the Final Rule provides an affirmative defense for any violation in tier 1 (unknown and 'unknowable' violations) and tier 2 (violations due to 'reasonable cause') if the violation is corrected within 30 days of the date the covered entity or business associate learned or should have learned of the violation."

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