On 4 August 2016 Advocate Health Care Network (‘Advocate’) agreed with the US Office of Civil Rights (‘OCR’) a $5.55 million settlement following enforcement by the OCR of the Health Insurance Portability and Accountability Act 1996 (‘HIPAA’) – a record settlement penalty. Advocate agreed as part of the settlement to a corrective action plan (‘CAP’), perhaps the most comprehensive in OCR settlement history. Kelly T. Hagan of Schwabe, Williamson & Wyatt analyse the settlement and the plan, and how they fit into trends around HIPAA enforcement.

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