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SESK: Stuff Everyone Should Know · sesk.info/hipaa-workforce-sanctions-required

What should happen if a workforce member violates security policies?

The organization must apply sanctions against that workforce member.

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  1. Apply sanctions to workforce who fail to comply ✔
  2. Fine patients who miss appointments
  3. Ignore the violation

Why: Security policies must include sanctions against workforce members who fail to comply with the entity's security policies and procedures.

Huh, didn't know that: The Privacy Rule has its own sanctions standard for privacy violations, in 45 CFR 164.530(e).

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Why did the compliance officer give a warning? Because sanctions are required, not optional.
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References

Answer: Apply sanctions to workforce who fail to comply. Security policies must include sanctions against workforce members who fail to comply with the entity's security policies and procedures.

  1. 45 CFR 164.308(a)(1)(ii)(C) www.ecfr.gov/current/title-45/subtitle-A/subchapter-C/part-164/subpart-C/section-164.308
    Apply appropriate sanctions against workforce members who fail to comply with the security policies and procedures...
    Checked 2026-10-10.

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