Eric Fader's comments appeared in an article, "Delayed Breach Notice Costs Illinois Health System," published in Bloomberg BNA's Privacy Law Watch. The article discussed a $475,000 settlement that Presence Health, an Illinois health system, reached with the Department of Health and Human Services' Office for Civil Rights (OCR) for failing to report a data breach in a timely manner. Fader told Bloomberg BNA that while not notifying the OCR timely may not be among the most serious of HIPAA violations, failing to notify the affected individuals within 60 days of a breach can be a major problem because it can prevent them from taking action to protect themselves. Fader said he didn't believe there would be more settlements of this type announced publicly, unless the OCR chooses to reinforce the point by publicizing a future settlement of a smaller breach affecting fewer than 500 people. Fader also observed that this breach involved paper records, unusual given the OCR's recent focus on breaches of electronic information.