Ira Parghi of Ropes & Gray writes:
Since January 2016, the OCR has entered into resolution agreements with, and imposed Corrective Action Plans (CAPs) on, providers and others in at least 12 matters involving the Security Rule. It has also imposed a Civil Monetary Penalty on one entity. Most of these cases involve stolen, unencrypted laptop computers (at least six cases), mobile devices such as iPads or iPhones, office computers, or portable storage devices.
Notably, while the underlying facts of these cases vary somewhat, their CAPs do not. All 12 of the CAPs hone in on the obligation under the Security Rule to perform an annual Risk Analysis and Risk Management Plan.
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