Late last month, the Office for Civil Rights in the Department of Health and Human Services (HHS) announced that Advocate Health Care Network had agreed to settle allegations that it failed to comply with various HIPAA data security requirements and to pay $5.55 million, the largest HIPAA fine to date.  The allegations stem from multiple incidents involving electronic protected health information (PHI).  According to HHS, the large settlement is due to “the extent and duration of the alleged noncompliance, the involvement of the State Attorney General in a corresponding investigation, and the large number of individuals whose information was affected.”