An increasing number of employer health plans are experiencing security breaches. Some of the causes are internal—lost staff unencrypted lap tops and mobile devices. Other causes are external—persistent and sophisticated hackers. New technology requires employers to reexamine their HIPAA privacy and security practices and policies to ensure ongoing compliance, including making sure all business associates are identified and making sure business associate agreements are in place with all of them. This is even more important now as HHS continues to pursue penalties and enters into settlement agreements with a growing number of employer health plans and business associates.

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