Penalty Amount
$5,000,000
Consumers Affected
6,100,000
New Jersey Attorney General settled with Community Health Systems, Inc. over a 2014 data breach affecting 6.1 million patients, including over 45,000 New Jersey residents. CHS will pay $5 million to 28 states and implement enhanced data security measures to protect personal and health information.
CHS must pay $5 million and implement a comprehensive data security program including an incident response plan, security and privacy training for personnel, access limitations to protected health information, and policies for business associates.
In-house legal teams should review all agreements involving personal health information (PHI), including vendor/business associate agreements (BAAs), patient consent forms, employment contracts for staff with data access, and any data processing agreements. Specific clauses to scrutinize are data security standards (e.g., encryption, access controls), breach notification timelines and procedures, data retention and disposal policies, audit rights for security compliance, and indemnification provisions for data breaches. Given the settlement's focus on enhanced protections, contracts may need updates to mandate specific technical safeguards (like encryption of SSNs), require regular third-party security audits, align breach notification with state laws (which may be stricter than HIPAA), and incorporate ongoing risk assessment obligations.
Entity
CHS/Community Health Systems, Inc.
Also known as: Community Health Systems
Industry
HealthcareOfficial Press Release
https://www.njoag.gov/ag-grewal-nj-reaches-settlement-with-community-health-systems-over-data-breach-acute-care-hospital-operator-will-improve-data-security-pay-penalty/
CHS NJ Complaint
https://www.nj.gov/oag/newsreleases20/CHS-NJ-Complaint.pdf
CHS NJ Final Consent Judgment
https://www.nj.gov/oag/newsreleases20/CHS-NJ-Final-Consent-Judgment.pdf
New Jersey Attorney General Enforcement Page
https://www.njoag.gov/about/divisions-and-offices/division-of-consumer-affairs/
"CHS/Community Health Systems, Inc."
"overall payment of $5 million"
"2014 data breach in which intruders copied and transferred data"
A multistate coalition co-led by New Jersey won a federal court order rejecting the Trump Administration’s decision not to request funding for the CFPB. The order struck down that decision and directed the Administration to follow the law and fund the agency; no monetary penalty or privacy violation is described.
New Jersey’s Attorney General and Division of Consumer Affairs alerted the public that three synthetic kratom-related compounds became illegal to possess or sell in the state under a temporary federal scheduling order. The release describes a controlled-substance alert, not a privacy enforcement action, and identifies no company, privacy violation, or monetary penalty.
$2.3M
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$694.0M
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$650K
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$96.5M
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