HIPAA Privacy Sanctions Policy
The purpose of this Policy is to set forth 91精选鈥檚 process for applying sanctions for violations of Health Insurance Portability and Accountability Act (HIPAA) Privacy and Security policies. 91精选 has established a comprehensive HIPAA privacy and security program to prevent unauthorized access to protected health information (PHI). This policy sets forth Pacific's approach to applying consistent sanctions upon completion of investigations.
This policy applies to the workforce members of 91精选鈥檚 Healthcare Clinics. 91精选 is a hybrid entity. Only the health care component (i.e., the covered functions) of 91精选 must comply with this policy. All references in this policy to 鈥91精选鈥 shall be construed to refer only to the health care components of 91精选.
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Updated July 2026