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Small Practices, Big Fines: Understanding HIPAA Penalties

July 7, 2025

 

Did you know that over half of physicians work in small medical practices with 10 or fewer physicians? 

You likely wear many hats when working in or even running your small practice, from taking care of patients to clerical work, and of course, HIPAA compliance. 

Although other priorities may push HIPAA compliance to the side, being compliant is essential for the success of your practice. 

It’s a common misconception that since a practice is small, the Office for Civil Rights (OCR) will not investigate it if an issue occurs. 

The OCR has fined several small practices recently, with ramped-up enforcement, nearing $10 million within the year’s first half. 

Here are some of the most recent fines imposed on small medical practices and how your practice can avoid them.

 

The SRA Superpower

Comprehensive Neurology, PC, a small neurology practice in New York, was recently fined $25,000 after a ransomware attack exposed the practice’s insufficient protections for securing Protected Health Information (PHI). Specifically, the practice did not have a Security Risk Analysis (SRA). 

The SRA is an annual assessment of your practice’s administrative, technical, and physical safeguards, reviewing potential vulnerabilities. When handled properly, the SRA allows you to mitigate risks before a situation occurs. 

While commonly missed, the SRA is the foundation of a successful practice.

To combat this, the OCR has recently enacted the Risk Analysis Initiative, which has brought increased scrutiny and led to nearly a million dollars in fines since its implementation late last year.

Completing an SRA is paramount to protect your small medical practice from similar initiatives. The SRA is a crucial protective barrier, proactively preventing issues before they escalate into significant problems. For instance, if the practice completed an SRA, they could have seen any technological shortcomings that led to the severity of the ransomware attack. 

 

Alert the Press! 

Vision Upright MRI, a small California healthcare provider focused on medical imaging, was fined $5,000 in May. 

In addition to missing an SRA following a breach, the small practice from California did not adequately inform patients. As part of the Breach Notification Rule, relevant parties, like impacted patients, the OCR, and, depending on the size of the breach, the media, and more, must all be notified following a breach. Patients can decide how to secure their information by being informed, and the practice should pay for credit monitoring. 

With over 21,000 patients’ PHI compromised, the practice needed to notify several parties quickly. Regardless of the breach’s size, a practice must inform all affected patients within 60 days of discovery. However, given that this breach affected over 500 patients, the OCR, media, and some states (like California), the state attorney general also required notification within that time frame.

Once you have mitigated the situation and understood the full scope, it’s time to alert all necessary parties. If the breach impacts fewer than 500 patients, while patients still need to be notified within 60 days, the practice must notify the OCR within 60 days of the calendar year in which it occurred. 

 

Deliver Records Swiftly 

Gums Dental Care LLC, a small dental practice in Maryland, was fined $70,000 after refusing to provide a patient’s medical records.  Under the HIPAA Privacy Rule, patients must receive their medical records within 30 days of request. This requirement, known as the Right of Access, is one of the most common violations. 

In this situation, Gums Dental Care provided records three years after the initial request. To avoid similar penalties, ensure all staff are trained efficiently to provide patient records. Quickly addressing patient requests prioritizes their needs, secures your practice, and builds patient trust.

 

Simplifying Compliance for Your Small Practice

While following the complexities of HIPAA might feel overwhelming, with the right solution, it doesn’t have to be. 

Intelligent software can streamline compliance for your practice, alleviating the responsibility and freeing time to spend with patients. 

Smart solutions also encompass HIPAA’s requirements, including the SRA, breach logs, and staff training. 

Schedule a consultation today to learn more about simplifying compliance for your small practice. 

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September 21, 2026   The HHS Office for Civil Rights (OCR) has announced its biggest HIPAA settlement of the year, reaching nearly a million dollars.  Ambry, a genetic testing and clinical genomics provider based in Aliso Viejo, California is at the center of this enforcement. A settlement was reached over a 2020 phishing attack that exposed the Protected Health Information (PHI) of more than 225,000 individuals. This settlement is a clear reminder that even large organizations trip up on HIPAA requirements.    What happened In January 2020, an employee email account at Ambry was compromised through a phishing attack.  The breach potentially exposed a wide range of PHI, including names, addresses, dates of birth, Social Security Numbers, financial details, and more. Ambry reported the breach to OCR in March 2020, which kicked off the investigation.    Where OCR found gaps OCR’s investigation identified several HIPAA Security Rule gaps, including: No accurate, thorough risk analysis of risks and vulnerabilities to ePHI No process for cutting off access to ePHI when an employee left or no longer needed access No unique user IDs for tracking who was accessing ePHI systems These are baseline HIPAA requirements that every Covered Entity and Business Associate is expected to have in place.   The settlement terms Ambry paid $700,000 and agreed to a two-year corrective action plan, under which it must: Complete a thorough risk analysis of ePHI confidentiality, integrity, and availability Build and execute a risk management plan addressing what that analysis turns up Review and update Security Rule policies and procedures as needed Implement unique user identification across all ePHI systems Train the whole workforce on those updated policies The takeaway for practices When 90% of healthcare hacks start with a successful phishing attempt, it’s key your team is aware of the role they play to keep data safe. Every practice should ask; Do we know exactly where our ePHI lives and how it moves through our systems? Do we have a current, documented risk analysis? Would we catch it fast if a former employee’s access wasn’t revoked? Looking for the first step of addressing these gaps? Meet with one of our compliance experts to see where you currently stand. 

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