HIPAA Interim Final Rule, October 30, 2009
Client Alert | less than 1 min read | 11.06.09
On October 30, 2009, the Department of Health and Human Services (HHS) published an interim final rule conforming HIPAA's enforcement regulations to revisions made under the HITECH Act. The interim final rule strengthens HHS' civil money penalty authority by establishing categories of violations reflecting levels of culpability, increasing the civil penalty amounts, and modifying the affirmative defenses available to covered entities.
Click here to view a presentation on the HIPAA Final Rule [PDF]
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DOJ Promises NPAs to Certain Individuals Through New Voluntary Self-Disclosure Pilot Program
On April 15, 2024, the Acting Assistant Attorney General for the Criminal Division of the Department of Justice (“DOJ”) Nicole Argentieri announced a new Pilot Program on Voluntary Self-Disclosure for Individuals (“Pilot Program” or “Program”). The Pilot Program offers a clear path for voluntary self-disclosure by certain corporate executives and other individuals who are themselves involved in misconduct by corporations, in exchange for a Non-Prosecution Agreement (“NPA”). The Pilot Program specifically targets individuals who disclose to the Criminal Division at DOJ in Washington, D.C. information about certain corporate criminal conduct. By carving out a clear path to non-prosecution for those who qualify, DOJ has created another tool to uncover complex crimes that might not otherwise be reported to the Department.
Client Alert | 3 min read | 04.23.24
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