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$2.15 Million Civil Money Penalty for HIPAA Violations

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The Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services imposed a $2,154,000 civil money penalty (CMP) against Jackson Health System (JHS) for violations of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Security and Breach Notification Rules, stemming from various instances of noncompliance that occurred between 2013 and 2016.

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October is National Cybersecurity Awareness Month

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October is National Cybersecurity Awareness Month (NCAM). NCAM serves as a timely reminder to continue to assess and improve organizational cybersecurity.

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Dental Practice Impermissibly Discloses PHI on Yelp

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Elite Dental Associates, Dallas (Elite Dental) and the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) entered into a $10,000 no-fault settlement agreement and two year corrective action plan to settle potential violations of the Health Insurance Portability and Accountability Act (HIPAA).

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Here Come the Proposed CCPA Regulations We’ve All Been Waiting For

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After a long wait, the California Attorney General’s (AG) office held a news conference on October 10, 2019, and published proposed regulations implementing the California Consumer Privacy Act (CCPA). Companies gearing up for CCPA’s January 1, 2020, effective date should quickly review and assess the proposed regulations’ potential effects on their operations and consider attending upcoming public hearings or submitting public comments by December 6, 2019.

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The FCC’s “Restoration of Internet Freedom Order” Largely Survives on Appeal; But Net Neutrality is Not Dead Yet

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On October 1, the U.S. Court of Appeals for the D.C. Circuit released a long awaited decision in Mozilla Corporation v. FCC that largely upheld most aspects of the Federal Communications Commission’s 2018 “Restoring Internet Freedom Order”  While FCC Chairman Pai quickly claimed victory, the nearly 200 page decision was in several areas quite critical of the FCC’s process, as well as the agency’s reasoning or the lack of discussion or support in the record for several of the Order’s determinations. Although these defects were not sufficient for the Court to reverse the Order on review, the Court nevertheless agreed with petitioners on several issues, discussed below, and remanded them to the agency for additional consideration.

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How We Spent Our Summer Vacation or Summary of CCPA Amendments

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The long anticipated amendments to the CCPA were passed by the California Legislature in early September and now await Governor Newsom’s signature.  Some of the changes were “clean up” amendments to update cross references, standardize language, and generally address issues of drafting.  What follows is a summary of the most significant and substantive amendments:

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