"[V]iolations of HIPAA can have implications well beyond HIPAA.... Health plans and their fiduciaries also may face [DOL] and other fiduciary claims ... The [DOL] followed up on previous warnings that health plan fiduciaries duties include a fiduciary duty to protect health plan data by adding HIPAA compliance to certain health plan audits. Insurers, third [party] administrators and others also can face duties and liabilities under state insurance and data privacy laws from regulator or private litigant actions."  MORE >>