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First HIPAA Settlement Involving a Business Associate: A Cautionary Tale
William Gallagher Associates 
July 12, 2016
"A business associate without access to large amounts of PHI, using widely available cost-per-record calculators, might conclude that it faces little financial exposure from the breach of a few hundreds or thousands of records and direct its cyber risk management investments accordingly. [A recent] enforcement action reflects OCR's desire to change that calculus, so that business associates give considerable weight to measures that will help make the breach of any PHI less likely."
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