Here’s a fantastic summary of the Phoenix Cardiac Surgery Group’s landmark HIPAA Violations penalty & settlement.

The days of small medical practices thinking they were too small for enforcement are (hopefully) over.


If your company needs another reminder that policies and procedures, risk assessments, documentation and training are critical elements for HIPAA compliance programs, we have another corrective action plan – and monetary fine – that should be utilized as a “teachable moment” for health care providers and business associates alike.

Phoenix Cardiac Surgery, P.C. has agreed to pay a $100,000 fine and implement a corrective action plan under a Resolution Agreement with the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) after a lengthy investigation into potential violations of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy and Security Rules.

OCR investigated the physician practice following a report that it had been posting clinical and surgical appointments on a publicly accessible Internet-based calendar. OCR’s investigation, dating back to 2003, found that Phoenix Cardiac Surgery had failed to implement sufficient policies and procedures to appropriately safeguard patient information. OCR also concluded that the physician practice did not adequately document employee training on the Privacy and Security Rules, identify a security official, conduct a risk analysis, or obtain satisfactory assurances in business associate agreements with Internet-based calendar and email providers. In a press release announcing the Phoenix Cardiac Surgery settlement, OCR Director Leon Rodriquez expressed the agency’s hope that health care providers “pay careful attention” to the Resolution Agreement and the expectation that all providers, “no matter the size,” fully comply with the Privacy and Security Rules.

via The Rising Cost of HIPAA Violations: $100,000 Fine Levied on Physician Group | Mintz Levin – Privacy & Security – JDSupra.