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Risk Of Accepting Out-Of-Scope Task/Delivery Orders Gets Greater

Client Alert | less than 1 min read | 10.07.04

Adding to the risk of accepting out-of-scope work that potentially could result in avoidance of the contract order, the GSA debarring official has recently put the burden on the contractor to police the situation: "We cannot have a situation where a contractor knows or should have known that something is wrong and does not at least raise the issue with the contracting officer, or, if appropriate, higher authority. On a case-by-case basis, if we determine that a contractor has not followed the rules, we may take appropriate action in the context of contractor responsibility."

Insights

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....