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|Be Careful What You Contract For: HIPAA and Successor Liability|
June 22, 2021
"On April 28, 2021, [OCR] ... entered into a resolution agreement ... to settle allegations of violations of the [HIPAA] Security Rule.... What is notable in this instance is that the investigation was not initiated because of a breach of unsecured Protected Health Information (PHI) ... Instead, the event that triggered the OCR investigation was a breach by Peachstate's acquirer, a business associate of a different covered entity."
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