April 2025 · OCR settlement
$350,000 — and the missing document drove the price.
In April 2025, a small New York radiology practice paid OCR $350,000 after reporting a 2020 hacking incident on its PACS server that exposed nearly 300,000 patients’ images. OCR’s investigation found no accurate, current risk analysis on file — the cited violation under 45 CFR § 164.308(a)(1)(ii)(A). It was the sixth settlement under OCR’s Risk Analysis Initiative, and the pattern is consistent: when an incident brings OCR in, the missing risk analysis is what drives the settlement amount.1
What the Risk Analysis Initiative means for you

