HHS Lowers Annual Caps on Most HIPAA CMPs

On April 30, 2019, the United States Department of Health and Human Services (HHS) published a notice of enforcement discretion that lowers most of the annual caps on civil money penalties (CMP). HHS may assess against Covered Entities and Business Associates for violating the Health Insurance Portability and Accountability Act of 1996, as amended (HIPAA).  Specifically, HHS will apply a different cumulative annual CMP limit for each of the four penalty tiers that progressively increases…