DOJHIPAA Enforcement Rule

HIPAA Criminal Enforcement (42 USC 1320d-6)

Criminal sanctions for knowingly obtaining or disclosing PHI in violation of HIPAA, enforced by the Department of Justice rather than HHS, with three tiers escalating to ten years' imprisonment.

Primary source

42 USC 1320d-6 — Office of the Law Revision Counsel

https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1320d-6&num=0&edition=prelim

Verified May 23, 2026 · This is the authoritative regulator URL. The summary below is a research aid; the linked source controls.

42 USC 1320d-6 sets criminal penalties for knowingly obtaining or disclosing individually identifiable health information in violation of HIPAA.

Three tiers:

  1. Base offense: knowingly violating — fine up to $50,000 and imprisonment up to one year.
  2. False pretenses: committing the offense under false pretenses — fine up to $100,000 and imprisonment up to five years.
  3. Intent to sell, transfer, or use for commercial advantage, personal gain, or malicious harm: fine up to $250,000 and imprisonment up to ten years.

DOJ — not HHS — prosecutes criminal HIPAA cases. Cases tend to involve workforce members selling celebrity records, identity-theft rings using stolen patient data, and intentional snooping followed by misuse. A 2005 DOJ memorandum extended criminal liability to individual employees (not only entities), settling an early interpretive question.

Coordination with civil enforcement: OCR can refer matters to DOJ; the DOJ frequently exercises declination, in which case OCR can proceed with civil enforcement. Conversely, an HHS civil settlement does not bar parallel state criminal action.

Criminal exposure is rare but real — and it lands on individuals, not just the entity.

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Last reviewed May 23, 2026 · Citation verified May 23, 2026

Research aid, not legal advice. This summary is an administrative research aid prepared by D3rx. It does not certify compliance, provide legal advice, replace counsel, or guarantee an audit outcome. For authoritative regulatory text follow the primary source link at the top of this page. The practice remains responsible for reviewing, adopting, and maintaining its compliance program.