On February 1, 2018, OCR announced the first HIPAA settlement of the year with Fresenius Medical Care North America (FMCNA), a national dialysis provider that also operates laboratories, emergency centers, and post-acoustic practices. Under the agreement, the organisation was required to implement substantial improvements in compliance, including the appointment of a compliance officer and the establishment of a compliance committee, as well as the implementation of specific compliance checks and verification procedures at board level.  HHS OIG reported that it viewed these types of requirements as a floor and not as a cap for supplier compliance programs. . . .