A key lesson to be learned from this case “is that the Office for Civil Rights can only be pushed so far when a covered entity or business associate is shown to have systemic, management-driven failures in putting into place safeguards to protect its health information,” says privacy attorney David Holtzman, vice president at the security consulting firm CynergisTek.
http://www.databreachtoday.com/32-million-hipaa-fine-analysis-a-9665
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