Instructions: You are the Assistant Deputy Regional Manager for the U.S. Department of Health and Human Services Office for Civil Rights (OCR). Six months ago, you received notification from Axe Health System about 4 breaches of PHI that occurred over the past year-and-a-half.
For the past six months, you have been investigating the 4 breaches of PHI that occurred at Axe Health System in order to draft a resolution agreement and your colleague has put together a Summary of the Events that occurred (see below).
After reading the Summary of the Events that occurred, please use the rules and regulations that comprise HIPAA and the resolution agreements that have been issued previously by OCR to write a brief 2-3 page memorandum to the Regional Manager about why each of the 4 breaches meet the definition of Breach under HIPAA, what an appropriate corrective action plan would be for Axe Health System, whether you think any civil fines should be assessed, and whether any issues should be sent to the U.S. Department of Justice for a criminal investigation. Also, please note whether Axe Health System followed all of the proper notification rules required under HIPAA.
Please cite specific sections of HIPAA and any resolution agreement that you use as an example to support your conclusions.