Some health care organizations have yet to take significant action to comply with the original HIPAA privacy and security rules, which were never vigorously enforced. Now that those rules have been beefed up under the American Recovery and Reinvestment Act, with increased enforcement and tougher penalties, many observers expect more hospitals, physician groups and others to gear up their data security assurance efforts.

"ARRA has given renewed focus on privacy and security, but many are not yet in compliance with the original HIPAA rules, much less the updated ones," says Kate Borten, president of the Marblehead (Mass.) Group, a security consulting firm.

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