HHS’ Office for Civil Rights Settles HIPAA Security Rule Investigation with Top of the World Ranch Treatment Center

Settlement Marks OCR’s 11th Enforcement Action in OCR’s Risk Analysis Initiative

WASHINGTON — February 19, 2026 — Today, the U.S. Department of Health and Human Services’ (HHS) Office for Civil Rights (OCR) announced a settlement with Top of the World Ranch Treatment Center (TWRTC), a substance use disorder treatment provider in Illinois, for a potential violation of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Security Rule.

OCR enforces the HIPAA Privacy, Security, and Breach Notification Rules (the HIPAA Rules), which set forth the requirements that covered entities (health plans, health care clearinghouses, and most health care providers) and business associates must follow to protect the privacy and security of protected health information (PHI). The HIPAA Security Rule establishes national standards to protect and secure our health care system by requiring administrative, physical, and technical safeguards to ensure the confidentiality, integrity, availability, and security of electronic PHI (ePHI). The Risk Analysis provision of the Security Rule requires covered entities and business associates to conduct an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of ePHI held by those organizations.

“In a time where health care providers and other HIPAA regulated entities are facing unprecedented cybersecurity threats, compliance with the HIPAA Risk Analysis provision is more essential than ever,” said OCR Director Paula M. Stannard. “Covered entities and business associates cannot protect electronic protected health information if they haven’t identified potential risks and vulnerabilities to that health information.”

The settlement resolves an investigation of TWRTC that OCR initiated after receiving a breach report that TWRTC filed in March 2023. TWRTC reported that, as a result of a successful phishing attack, an unauthorized third party accessed ePHI through a workforce member’s email account. TWRTC concluded that the ePHI for 1,980 patients was compromised by the attack. OCR’s investigation found evidence that TWRTC failed to conduct an accurate and thorough risk analysis to determine the potential risks and vulnerabilities to the confidentiality, integrity, and availability of the ePHI TWRTC holds as required by the HIPAA Security Rule.

Under the terms of the resolution agreement, TWRTC agreed to implement a corrective action plan that OCR will monitor for two years, and paid $103,000 to OCR. Under the corrective action plan, TWRTC committed to take steps to ensure compliance with the HIPAA Rules and protect the security of ePHI, including:

• Conduct and complete an accurate and thorough risk analysis to determine the potential risks and vulnerabilities to the confidentiality, integrity, and availability of its ePHI;
• Develop and implement a risk management plan to address and mitigate security risks and vulnerabilities identified in its risk analysis;
• Develop, maintain, and revise, as necessary, written policies and procedures to comply with the HIPAA Privacy, Security Rule, and Breach Notification Rules; and
• Provide annual training for workforce members who have access to ePHI on its written HIPAA policies and procedures.

OCR recommends that HIPAA covered health care providers, health plans, clearinghouses, and business associates implement the following steps to mitigate or prevent cyber-threats:

• Identify where ePHI is located in the organization, including how ePHI enters, flows through, and leaves the organization’s information systems.
• Periodically conduct, and update as needed, a risk analysis and develop and implement risk management measures to address identified risks and vulnerabilities to the confidentiality, integrity, and availability of ePHI.
• Ensure audit controls are in place to record and examine information system activity.
• Implement regular review of information system activity.
• Utilize mechanisms to authenticate users seeking access to ePHI.
• Encrypt ePHI in transit and at rest to guard against unauthorized access to ePHI when appropriate.
• Incorporate lessons learned from incidents into the organization’s overall security management process.
• Provide workforce members with regular HIPAA training that is specific to the organization and to the workforce members’ respective job duties.

The resolution agreement and corrective action plan may be found at: https://www.hhs.gov/sites/default/files/ocr-ra-cap-twrtc.pdf

OCR is committed to enforcing the HIPAA Rules that protect the privacy and security of individuals’ protected health information. Please see OCR’s guidance and webinar on the HIPAA Security Rule Risk Analysis requirement.

If you believe that your or another person’s health information privacy or civil rights have been violated, you can file a complaint with OCR.

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