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Are QR Codes Enough? NPP Accessibility
QR codes are increasingly used to provide access to the HIPAA Notice of Privacy Practices—but convenience alone doesn’t guarantee compliance. While digital access can support modernization, HIPAA still requires the NPP to be prominent, accessible, and available to all patients. This post explains when QR codes help, where they fall short, and how organizations can meet both the letter and spirit of the Privacy Rule.

Jessica Zeff
Feb 202 min read


After Death: Navigating Compliance When Legal Authority Is Unclear
Requests for access to a deceased patient’s medical records are common—but often misunderstood. HIPAA protections continue for 50 years after death, and disclosure depends on legal authority and specific regulatory pathways. This post explains when records may be released, what documentation is required, how state law factors in, and why organizations should approach these requests with both empathy and clear compliance guardrails.

Jessica Zeff
Feb 133 min read


Illinois AG Charges Cook County Physician in $1 Million Fraud Case: Implications for Compliance Programs
In November 2025, the Illinois Attorney General announced felony charges against a Cook County physician accused of orchestrating a scheme to defraud Medicaid and Medicare of more than $1 million. According to the press release, the physician allegedly submitted reimbursement claims for services that were not provided or were delivered by an unlicensed medical student rather than by the physician himself. The charges include theft, money laundering, managed care fraud, vendor

Jessica Zeff
Feb 73 min read


Thinking About Epic Cosmos? What to Ask Before You Plug In
Epic Cosmos offers unprecedented access to de-identified clinical data, enabling large-scale research and population health insights. But for compliance teams, participation raises important questions about transparency, patient trust, and risk oversight. This post explores what organizations should consider before joining Cosmos—from opt-out decisions and privacy notices to risk assessments and staff training—so innovation doesn’t outpace governance.

Jessica Zeff
Jan 303 min read


OCR Revisits Risk Management Under HIPAA
OCR’s renewed focus on risk management under the HIPAA Security Rule signals a clear shift in enforcement priorities. Risk analysis and mitigation are no longer treated as background compliance tasks, but as foundational requirements subject to direct scrutiny—even absent a breach. This post explains why OCR is revisiting risk management, what recent enforcement actions reveal, and what compliance and security leaders should be doing now to avoid preventable penalties.

Jessica Zeff
Jan 232 min read


Why Every Healthcare Organization Needs an AI Policy
Artificial intelligence is already embedded in healthcare operations, often without a formal decision to adopt it. From EHR upgrades to billing tools and vendor platforms, AI shows up quietly and introduces real compliance risk. An AI policy helps organizations understand where AI is used, what data it touches, and who is responsible. Without clear rules and oversight, even well-intentioned AI use can create regulatory exposure.

Jessica Zeff
Jan 192 min read


What to Watch in 2026
As healthcare heads into 2026, the regulatory story is less about new rules and more about follow-through. Coverage churn, interoperability expectations, utilization management scrutiny, and technology oversight are all becoming operational realities rather than policy debates. This post outlines the compliance and operational pressure points organizations should be watching—from eligibility verification and prior authorization to vendor oversight, HIPAA security, and documen

Jessica Zeff
Jan 183 min read


What’s Coming with SUD Records: Preparing for the 2026 42 CFR Part 2 Changes
The 2026 compliance deadline for updated 42 CFR Part 2 regulations is fast approaching, and organizations handling substance use disorder records can no longer afford to wait. While the rule introduces greater alignment with HIPAA—such as single consent for treatment, payment, and operations—it also preserves heightened protections for SUD counseling notes and legal disclosures. This post breaks down what has changed, what hasn’t, and what compliance teams should be doing now

Jessica Zeff
Jan 165 min read


When Law Enforcement Shows Up: Why Hospitals Need Clear, Written Protocols—Now
When law enforcement enters a hospital, uncertainty can escalate into immediate compliance risk. From unconscious patients to unclear legal authority, these encounters expose gaps in policy, training, and escalation protocols. As regulators sharpen their focus, hospitals can no longer rely on judgment calls or informal practices. This post outlines why clear, written law enforcement protocols are now a compliance imperative—and what programs must address to protect patients,

Jessica Zeff
Jan 93 min read


Texas Drops Challenge to HIPAA Privacy Rule
Texas’s decision to abandon its lawsuit challenging the HIPAA Privacy Rule removes a major source of regulatory uncertainty for healthcare organizations. While recent court action vacated the 2024 reproductive health amendments, the core HIPAA Privacy Rule remains intact and legally resilient. For compliance leaders, this outcome reinforces HIPAA as the enduring baseline standard while highlighting the ongoing tension between state and federal privacy authority.

Jessica Zeff
Jan 22 min read


$46 Million — A Hard Lesson on Web Tracking and Patient Privacy
According to recent reporting, Kaiser Permanente agreed to pay at least $46 million (potentially up to $47.5 million) to settle a class‑action lawsuit alleging it improperly shared patient data via tracking technologies embedded in its websites, mobile apps, and patient portals. Specifically: The health system used cookies, pixels, and other “web‑tracking tools” on pages likely to handle or display protected health information (PHI), rather than limiting them to purely publi

Jessica Zeff
Dec 26, 20253 min read


CVS to Return Over $37.7 Million
CVS’s $37.76 million settlement over insulin pen dispensing is more than a headline—it’s a clear enforcement signal. Allegations of overdispensing, inaccurate days-of-supply reporting, and systemic billing failures highlight how packaging, dosing complexity, and automation can quietly create compliance risk. For pharmacies, health systems, and payers, the case reinforces why billing accuracy, documentation, and operational oversight are non-negotiable.

Jessica Zeff
Dec 19, 20252 min read


Why a HIPAA Security Risk Assessment Is the Foundation of a Modern Information Security Program
Many healthcare organizations still treat the HIPAA Security Risk Assessment as a compliance checkbox. That approach is increasingly risky. In today’s threat environment, a thorough security risk assessment is the foundation of a modern information security program—helping organizations identify vulnerabilities, prioritize resources, and protect not just PHI, but the financial, operational, and strategic data that keeps the organization running.

Jessica Zeff
Dec 16, 20253 min read


“Everyone Over 70 Has Kidney Failure”: How Independent Health’s Risk Adjustment Scheme Went Off the Rails
A shocking whistleblower case revealed that Independent Health and its subsidiary DxID inflated risk scores through unsupported diagnoses, improper coding sources, and pressured provider addenda. The result: nearly $100 million returned to Medicare. This blog breaks down how the scheme worked, why it failed, and what compliance professionals must learn from it.

Jessica Zeff
Dec 13, 20254 min read


Understanding the OIG’s Information Blocking Enforcement Alert
OIG’s new Information Blocking Enforcement Alert signals a shift from education to action. With penalties now in play, compliance teams must reassess workflows, exceptions, vendor contracts, and staff training to ensure EHI flows appropriately. This is a key moment for compliance, IT, privacy, and operations to align around safe, timely access to health information.

Jessica Zeff
Dec 5, 20252 min read


Compliance and Risk Management: Two Roles, One Responsibility
In today’s complex regulatory landscape, compliance and risk management can no longer work in silos. Each provides essential data and context to the other—compliance identifies risks, while risk management prioritizes them. Together, they create a proactive defense that protects healthcare organizations from costly penalties, reputational damage, and governance gaps while strengthening overall organizational resilience.

Jessica Zeff
Dec 2, 20253 min read


Fiduciary Duty and Board Management: What Compliance Officers Need to Know
In this episode of Compliance Deconstructed, we unpack fiduciary responsibilities and board governance essentials. Jessica Zeff and Elvan Baker explain how compliance officers can support their boards, clarify duty of care and loyalty, and create structures that promote transparency and accountability. Whether you're new to board management or facing governance challenges, this episode offers practical, actionable insight.

Jessica Zeff
Nov 25, 20253 min read


Understanding the Three Lines of Defense in Healthcare Compliance
The Three Lines of Defense model defines clear roles in managing healthcare compliance and risk. Operational teams own the process, compliance provides oversight, and internal audit ensures accountability. When these roles align, organizations reduce risk, strengthen governance, and create programs that prevent issues before they arise—building a sustainable culture of accountability and continuous improvement.

Jessica Zeff
Nov 4, 20253 min read


AI in Prior Authorization: Balancing Innovation and Oversight
AI tools promise faster, cheaper prior authorization decisions—but at what cost? The UnitedHealth lawsuit highlights how algorithms can increase denials and harm patients when oversight lags behind innovation. Compliance leaders must ensure AI decisions remain transparent, clinically sound, and patient-centered. The goal isn’t to reject technology—it’s to balance efficiency with ethical, accountable care.

Jessica Zeff
Oct 31, 20253 min read


What UnitedHealth’s Expanding DOJ Probe Means for the Rest of Us
The expanding DOJ investigation into UnitedHealth now spans Medicare billing, PBM practices, and provider relationships—signaling a new era of compliance risk. For healthcare organizations, the message is clear: documentation, internal audits, and oversight across interconnected business lines must be airtight. Transparency and proactive compliance aren’t just protective—they’re strategic necessities.

Jessica Zeff
Oct 24, 20252 min read
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