WASHINGTON, D.C. — The U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR), has reached a resolution agreement with Holy Redeemer Family Medicine, a Pennsylvania-based healthcare provider, over allegations of violating the HIPAA Privacy Rule. This settlement arises from an unauthorized disclosure of a patient’s protected health information (PHI), which included sensitive reproductive health details.
Details of the Alleged Violation
The case stems from a September 2023 complaint filed with OCR. The complaint alleged that Holy Redeemer impermissibly disclosed a female patient’s full medical record to a prospective employer, including sensitive information such as her surgical, gynecological, and obstetric history. According to the complainant, she had specifically requested that only one test result, unrelated to her reproductive health, be sent to the employer. OCR’s investigation found that Holy Redeemer failed to obtain the patient’s authorization for the broad release of her PHI and had no other applicable justification under HIPAA’s Privacy Rule for such a disclosure.
The HIPAA Privacy Rule establishes national standards to safeguard individual health records and restricts the use and disclosure of PHI without patient authorization, except in specific circumstances such as law enforcement or health oversight activities. According to OCR, Holy Redeemer’s actions represented a clear breach of these standards.
Settlement and Corrective Actions
Under the terms of the resolution agreement, Holy Redeemer has agreed to pay $35,581 and implement a comprehensive corrective action plan to prevent similar incidents in the future. OCR will closely monitor the organization’s compliance with these measures over a two-year period. The corrective actions include the following:
- Submission of a breach notification report detailing the incident to HHS;
- Review and revision of policies and procedures to ensure alignment with the HIPAA Privacy Rule, with these updates subject to HHS approval;
- Distribution of updated policies to all workforce members, accompanied by certification of receipt and understanding from each member;
- Mandatory workforce training on the revised policies and procedures;
- Submission of a written report to HHS, within 120 days of approval, on the implementation status of the corrective action plan;
- Reporting instances of non-compliance with updated policies and procedures;
- Submission of annual compliance reports to OCR for the duration of the monitoring period.
OCR Statement on the Breach
OCR Director Melanie Fontes Rainer underscored the importance of adherence to HIPAA regulations, especially in protecting sensitive health information. “It is imperative that health care providers take their duty to protect patient privacy seriously and follow the law,” said Fontes Rainer. “Patients must be able to trust that sensitive, health information in their files is protected to preserve their trust in the patient-doctor relationship and ensure they get the care they need. This is particularly true for reproductive health privacy.”
Ongoing Commitment to HIPAA Enforcement
This settlement illustrates OCR’s efforts to ensure compliance with HIPAA regulations. By addressing breaches and holding healthcare providers accountable for safeguarding PHI, OCR aims to strengthen public trust in the healthcare system and ensure that patients’ privacy is respected.
Holy Redeemer’s compliance with the terms of this resolution agreement will be closely monitored, setting a precedent for upholding the protections outlined in the HIPAA Privacy Rule. This case also serves as a reminder to all covered entities of the critical responsibility to prioritize patient privacy and maintain rigorous safeguards for protected health information.
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