In addition to the $1.5 million settlement, BCBS must:
One of the requirements calls for BCBS to randomly audit facilities using portable devices.
"That's really something I have not seen before," said Ali Pabrai, MSEE, CISSP, chief executive of ecfirst, home of The HIPAA Academy. "They are making them randomly audit their facilities that house portable devices. The fact they are saying it should be done randomly and unannounced shows they are serious about this."
The interim final rule on breach notification went into effect only months before the BCBS breach. Pabrai says entities should take note that OCR is willing to go back years to investigate breaches.
"Go back and get as much detail as you can," Pabrai says of earlier breaches reported to OCR. "You've got to be ready for this."