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White House and Military Departments Release Guidance as (Another) Budget Deadline Approaches

Client Alert | 1 min read | 01.18.13

In the past week, OMB, DoD, Army, Air Force, and Navy have all released guidance directing their subordinate entities to begin planning for the possibility of sequestration (presently scheduled to result in the cancellation of approximately $85 billion in FY13 budgetary resources) beginning on March 1, 2013, and for the expiration of the FY13 Continuing Appropriations Resolution (which expires on March 27, 2013, and must either be extended or replaced with new appropriations acts to prevent a lapse in appropriations and government shutdown). While the guidance cautions that efforts to prevent sequestration and ensure continued appropriations are underway, the memos acknowledge that, as a practical matter, agencies must begin planning for the possibility that they will need to operate with dramatically reduced budgetary resources.


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....