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Disharmony in the Cyber Acquisition Patchwork

Client Alert | 1 min read | 05.07.15

While Executive Order No. 13636 asked for a review of "what steps can be taken to harmonize" existing cyber regulations governing federal acquisitions, a patchwork of more than a dozen different agency regulations – and dozens upon dozens of unpublished cyber policies – impose heavy burdens upon contractors seeking to build cost-effective cybersecurity compliance programs. On May 11, C&M's David Z. Bodenheimer will discuss this analysis and lead a co-sponsored program for the ABA Public Contract Law Section's Cybersecurity, Privacy, and Information Security Committee and the Science & Technology Law Section's Homeland Security Committee on "The Cybersecurity Patchwork of Federal Agency Rules & Unpublished Policies: How Do Contractors Comply?"

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....