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University of Washington Medicine Agrees to $750,000 HIPAA Settlement

December 15, 2015
by Heather Landi
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The University of Washington Medicine (UWM), based in Seattle, Wash., has agreed to pay $750,000 to settle charges that it potentially violated the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Security Rule stemming from a security breach in 2013.

According to the charges, UWM potentially violated the HIPAA Security Rule by failing to implement policies and procedures to prevent, detect, contain, and correct security violations. As part of the settlement, UWM agreed to a corrective action plan and will submit annual reports on its compliance efforts.

The U.S. Department of Health and Human Services Office for Civil Rights (OCR) initiated an investigation of UWM following a breach report on Nov. 27, 2013, which indicated that the electronic protected health information (e-PHI) of approximately 90,000 patients had been accessed.

The breach occurred after an employee downloaded an email attachment that contained malicious malware. The malware compromised the organization’s IT system, affecting the data of two different groups of patients -- approximately 76,000 patients involving a combination of patient names, medical record numbers, dates of service, and/or charges or bill balances; and also approximately 15,000 patients involving names, medical record numbers, other demographics such as address and phone number, dates of birth, charges or bill balances, social security numbers, insurance identification or Medicare numbers, according to the HHS website.

The OCR stated that this newest settlement shows the need for organization-wide risk analysis.

“All too often we see covered entities with a limited risk analysis that focuses on a specific system such as the electronic medical record or that fails to provide appropriate oversight and accountability for all parts of the enterprise,” OCR director Jocelyn Samuels said in a statement.  “An effective risk analysis is one that is comprehensive in scope and is conducted across the organization to sufficiently address the risks and vulnerabilities to patient data.”

OCR’s investigation indicated UWM’s security policies required its affiliated entities to have up-to-date, documented system-level risk assessments and to implement safeguards in compliance with the Security Rule.  However, according to OCR, “UWM did not ensure that all of its affiliated entities were properly conducting risk assessments and appropriately responding to the potential risks and vulnerabilities in their respective environments.”

Two weeks ago, Lahey Hospital and Medical Center agreed to pay $850,000 to settle potential HIPAA security violations due to a 2011 security breach.





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