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The purpose of this Policy is to set forth 51����’s process for applying sanctions for violations of Health Insurance Portability and Accountability Act (HIPAA) Privacy and Security policies. 51���� 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 51����’s Healthcare Clinics. 51���� is a hybrid entity. Only the health care component (i.e., the covered functions) of 51���� must comply with this policy. All references in this policy to “51����” shall be construed to refer only to the health care components of 51����.

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Updated April 2025