Corrective Action Plans: What They Reveal About the State of HIPAA Compliance in America
- Patient Protect
- 4 days ago
- 3 min read
When a healthcare organization violates HIPAA, the consequences extend far beyond a headline or a fine. Behind every breach reported to the U.S. Department of Health and Human Services (HHS) lies a lesser-known but powerful accountability mechanism: the Corrective Action Plan (CAP).
At Patient Protect, we recently launched a public HIPAA Breach Dashboard that not only visualizes every reported HIPAA incident—but also includes CAPs of those breaches. What we’ve uncovered is sobering, and essential for every healthcare practice to understand.
What is a Corrective Action Plan (CAP)?
A Corrective Action Plan is a legally binding remediation strategy imposed by the HHS Office for Civil Rights (OCR) on covered entities or business associates who violate HIPAA regulations. CAPs are not simply suggestions—they are contractual obligations that typically include:
Detailed security and privacy overhauls
Mandatory employee training programs
Independent monitoring and reporting
Implementation of risk assessments
Systematic policy and procedure revisions
Significant financial settlements
In short, a CAP is OCR’s way of saying: “You failed to protect patient data, and now you need to prove that won’t happen again.”
Why CAPs Matter: A Hidden Indicator of Systemic Risk
Most compliance tools stop at fines and headlines. But CAPs go deeper. They tell a story of why a breach happened and what’s missing inside the organization. That’s why we believe displaying CAPs on the Patient Protect Dashboard is more than just informational—it’s transformational.
Here are just a few real-world insights drawn from the dashboard’s CAP data:
A large dental chain was breached due to lack of encryption and failure to perform risk analysis. The CAP required full encryption implementation and 2 years of independent audits.
A multi-location clinic suffered a breach from unauthorized access. Their CAP involved revamping workforce training, conducting frequent access reviews, and deploying role-based access controls.
A specialty provider lost unencrypted backup media. OCR mandated secure transport protocols and new physical safeguards, along with a complete inventory of all stored PHI.
CAPs show where the guardrails failed—and how to fix them.
What Our Dashboard Uncovered
We analyzed reported CAPs from public data. The most common failures?
Failure Type | % of CAPs Citing This |
Risk Analysis Not Conducted | 61% |
Inadequate Policies & Training | 49% |
Improper Access Management | 42% |
Lack of Encryption | 34% |
No Business Associate Controls | 28% |
What’s alarming is that many of these failures are preventable with simple, modern tooling. Most small practices simply lack the security infrastructure, documentation processes, or compliance guidance needed to stay ahead.
The Real Cost of a CAP
A CAP isn’t just a paperwork burden. It’s a multi-year commitment, often requiring:
Outside consultants
Monthly audits
Public transparency
Ongoing legal exposure
And the financial toll can range from $50,000 to $3 million or more, depending on the size and scope of the breach. The worst part? Most of these practices thought they were HIPAA compliant.
What Makes Patient Protect Different
At Patient Protect, we’ve studied the CAPs so you don’t have to suffer one.
Our platform is built specifically to prevent the root causes that trigger OCR enforcement and CAPs in the first place. From automated risk assessments to built-in policy generation and employee training, our system proactively addresses what others overlook.
We even track live CAPs and breach cases across the country so you can benchmark your clinic’s risk profile against real-world threats.
Transparency Is Power
The reason we made our HIPAA Breach Dashboard free and public is simple: clarity leads to accountability. By studying CAPs, clinics can learn from others’ mistakes before OCR comes knocking.
So don’t just stay “compliant.” Stay informed. Stay secure. Stay ahead.
Explore the Dashboard
See real CAPs. Track trends. Benchmark your risks. View the HIPAA Breach Dashboard
