2016 HIPAA Settlements Demonstrate HIPAA Compliance Challenges in a Mobile Society

The U.S. Department of Health and Human Services, Office for Civil Rights (“OCR”) has been actively enforcing the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) in 2016. As of August, covered entities and business associates (the organizations who are subject to HIPAA) have paid OCR more than $20 million to resolve allegations of