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© Clearwater Compliance LLC | All Rights Reserved Copyright Notice 1 Copyright Notice. All materials contained within this document are protected by United States copyright law and may not be reproduced, distributed, transmitted, displayed, published, or broadcast without the prior, express written permission of Clearwater Compliance LLC. You may not alter or remove any copyright or other notice from copies of this content. For reprint permission and information, please direct your inquiry to

© Clearwater Compliance LLC | All Rights Reserved Legal Disclaimer 2 Legal Disclaimer. This information does not constitute legal advice and is for educational purposes only. This information is based on current federal law and subject to change based on changes in federal law or subsequent interpretative guidance. Since this information is based on federal law, it must be modified to reflect state law where that state law is more stringent than the federal law or other state law exceptions apply. This information is intended to be a general information resource regarding the matters covered, and may not be tailored to your specific circumstance. YOU SHOULD EVALUATE ALL INFORMATION, OPINIONS AND ADVICE PROVIDED HEREIN IN CONSULTATION WITH YOUR LEGAL OR OTHER ADVISOR, AS APPROPRIATE. The existence of a link or organizational reference in any of the following materials should not be assumed as an endorsement by Clearwater Compliance LLC.

© Clearwater Compliance LLC | All Rights Reserved Case Study Pre-read 3 1.Read the following A.ISU OCR Notice Letter from OCR B.April 5, 2013 Idaho State University Resolution Agreement & Corrective Action Plan C.Idaho State University Settles HIPAA Security Case for $400,000 2.Answer Questions on Following Page

© Clearwater Compliance LLC | All Rights Reserved Homework Questions 4 1.Based on your readings, answer these questions: A.What triggered the OCR Investigation? B.How long did the investigation last? C.What was the root cause of the issue? D.Was there a “Breach”? E.Was the new Civil Monetary Penalty System used to determine the settlement amount? F.What key requirements were set forth in the Corrective Action Plan? G.What, if anything, was surprising about the case?