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How would the fines and penalties be determined? Can an employee be fined separate from the agency involving the same fine?

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How would the fines and penalties be determined? Can an employee be fined separate from the agency involving the same fine?

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(A) Office of Civil rights/feds determine HIPAA penalty. DMH determines employee discipline. May also create private cause of action (private law suit). Both agency and employee are exposed to liability.

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