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Zero Hour: Contractors Face Increased FCA Exposure for Cybersecurity Noncompliance

Client Alert | less than 1 min read | 09.25.19

Along with the steady influx of cybersecurity requirements in federal procurement, contractors now face potential False Claims Act (FCA) liability in connection with cybersecurity noncompliance. Underscoring this risk was a recent FCA settlement, United States, ex rel. Glenn v. Cisco Sys. Inc., in which Cisco agreed to pay $8.6 million to settle allegations that it violated the FCA by selling products to the government that contained flawed software that was susceptible to data breaches. 

In an article published in Bloomberg Law, C&M attorneys discuss the intersection of the FCA and cybersecurity requirements as well as strategies to mitigate risk and defend against cybersecurity based FCA actions.

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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....