The report has eleven recommendations for the Church including getting the right support
in place for survivors, the leadership
of bishops, strengthening guidance, reviewing the Archbishops»
Lists and the effectiveness
of disciplinary measures with regards to
safeguarding related cases.
The comments
in the Proposed Rule
listed examples
of willful neglect as: (1) disposal
of a hard drive
in an unsecured dumpster where the covered entity failed to implement policies and procedures to
safeguard PHI during the disposal process; (2) failure to respond to an individual's request for restriction
of the uses
of PHI where the covered entity did not have any policies and procedures
in place for consideration
of the request for restriction; (3) a covered entity's employee loses a laptop that contains unencrypted PHI and the covered entity feared for its reputation if the incident became public and decided not to provide the appropriate notification.7