I’ve been surprised when the Department of Health and Human Services’ Office for Civil Rights lowers the boom and heavily fines a health care organization for violations of HIPAA rules following a major breach of protected health information. Surprised because it has only happened a handful of times and there are now 400 major breaches listed on the OCR public Web site.

But I’m flabbergasted, for different reasons, with the OCR’s latest move--Blue Cross Blue Shield of Tennessee getting hit with a $1.5 million fine in addition to agreeing to a corrective action plan.

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