Failure to conduct a risk analysis and develop a risk management plan as required under the HIPAA privacy and security rules has landed a provider organization in trouble with the HHS Office for Civil Rights, leading to a $400,000 fine and imposition of a three-year corrective action plan.

Metro Community Provider Network is a large federally qualified health center with 21 clinics serving 43,000 primarily poor patients in five counties throughout the Denver region. Its services include primary care, dental, pharmacy, social work and behavioral health.

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