Computer Security

While it is important to comply with all of the mandates of the Omnibus Rule, I think it is instructive to know from where the most vulnerable areas of breach of PHI arise.

In a recent presentation to a limited number of attorneys in which I participated, an investigator for the Office for Civil Rights (OCR) advised that with respect to breach notification of major HIPAA breaches (those in which the PHI of 500+ individuals had been disclosed), as of February 27, 2015, OCR’s records indicate that the following were the percentages attributable to the causes/circumstances for those breaches:

  1. Paper records 22%
  2. Laptop 21%
  3. Desktop computer 12%
  4. Network server 12%
  5. Portable Electronic device 11%
  6. Email 7%
  7. EMR 4%
  8. Other 11%
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