The Omni-bus rule is:
• Finalization of interim rules outlined in the HITECH act
• Formalizes enforcement provisions for breaches
• Expands definition of BA to include subcontractors of BA (BA of BA)
• Clarifies that HHS will determine the actual maximum for penalties
• Covered Entities (CE) and BA are liable for the acts of BA and their subcontractors
• Requires an on-going monitoring process for the organization’s security programs and processes.