OCR continues setting examples with the recent announcement of the $4,348,000 civil money penalty (CMP) that they imposed on MD Anderson. A review of the details shows us once again that the enforcement of HIPAA obligations is not something they decide to do in a willy-nilly way. It is specific and designed to set examples of what is expected. Most headlines are about that $4.3 million in penalties but to us, that is not what is the most interesting and important thing to note in this case.

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