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HIPAA Breach Notification: When and How to Self-Report
Holland & Hart LLP 
[Guidance Overview] Jan. 9, 2019
"Under the breach notification rule, covered entities are only required to self-report if there is a 'breach' of 'unsecured' PHI.... [T]he covered entity or business associate must determine the following: Was there a violation of the privacy rule? ... Does the violation fit within breach exception? ... Is there a 'low probability that the data has been compromised?' ... When in doubt, it is likely safer to report."
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