Covered entities which experienced a HIPAA breach in calendar year 2015 are required to report all such breaches affecting fewer than 500 individuals to OCR by Monday, February 29, 2016. The reports must be submitted via OCR’s online portal, available here. This yearly reporting obligation is in addition to the requirement to report large breaches — those affecting 500 or more individuals — within 60 days of discovering the breach.

This is also an appropriate time to review and update breach notification policies and procedures to make sure that covered entities have in place the appropriate mechanisms to notify OCR timely and appropriately.