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FY 2019 NDAA – Cyber Focus

Client Alert | 1 min read | 08.20.18

The 2019 National Defense Authorization Act (NDAA) includes a robust set of cybersecurity provisions impacting the Defense Industrial Base, including:

  • Encouraging federal agencies to avoid using lowest price technically acceptable source selection criteria in procurements predominately for the acquisition of information technology and cybersecurity services.
  • Establishing a pilot program to oversee Controlled Unclassified Information (CUI) handled by contractors with foreign ownership, control, or influence.
  • Requiring DoD to notify Congress of data breaches involving significant losses of Personally Identifiable Information (PII) or other forms of CUI.
  • Encouraging DoD and the National Institute of Standards and Technology (NIST) to assist small businesses in the Defense Industrial Supply Chain by enhancing cyber threat awareness and training, and helping to conduct voluntary cybersecurity self-assessments.
  • Requiring DoD to obtain disclosures from vendors regarding foreign government access to products or source codes, before acquiring their cybersecurity or information technology products and services.

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Client Alert | 7 min read | 08.17.26

Delayed Notification of Cyberattacks May Trigger HIPAA Breach Notification Rule

After identifying a ransomware attack in 2021, OSF Healthcare System waited until its forensic investigation had concluded before notifying the U.S. Department of Health and Human Services (HHS) — and the affected individuals — of the breach. The 110-day delay (nearly double the 60-calendar-day notification deadline mandated by the HIPAA Breach Notification Rule) triggered an investigation from HHS’s Office for Civil Rights (OCR). The health system’s investigation determined that protected health information (PHI) had been stolen....