Follow-Up Obligations Worse Than Fines In HIPAA Violations

While Massachusetts General Hospital got socked with a $1 million HIPAA penalty when an employee left 192 patient records in the open on a subway seat, the penalty is perhaps not the worst of the consequences.

MASS General also was required to sign a Corrective Action Plan that will have the Office of Civil Rights tightly monitoring every move at the facility for HIPAA compliance.  The conditions include:

  •  Three (3) years of reporting requirements to OCR
  • Adoption of new policies and procedures which meet OCR approval
  • Unannounced site inspections
  • OCR interviews with MGH workforce members who work with PHI
  • OCR interviews with staff working with the corrections
  • Inspection of laptops, USB drives, and other equipment used for PHI
  • Monitoring training, implementation, and enforcement
  • Semi-annual reports
  • Self-reporting of violations
  • 120 day status report on the CAP

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