Court Rules
All enforcement actions
SettlementCritical Risk

CA AG Settles Kaiser for $49M Over Illegal Waste, PHI Disposal

Kaiser Foundation Health Plan, Inc. and Kaiser Foundation HospitalsSeptember 8, 2023California Attorney General

Penalty Amount

$49,000,000

Summary

California Attorney General Rob Bonta announced a $49 million settlement with Kaiser for illegally disposing of hazardous waste, medical waste, and protected patient information at facilities statewide. The settlement resolves allegations of violations under health privacy and environmental laws, requiring Kaiser to pay penalties, implement compliance measures, and undergo independent audits.

Remedy

Kaiser must pay $49 million in civil penalties, attorneys' fees, and supplemental environmental projects; retain an independent third-party auditor to conduct at least 520 trash compactor audits and 40 annual programmatic audits for five years; and implement enhanced environmental compliance measures at its California facilities.

Monetary PenaltyAudit RequirementCompliance Program

Contract Impact

In-house legal teams should review all vendor and facility management agreements, particularly those with waste disposal contractors, janitorial services, and document destruction vendors. Key clauses to examine include: (1) data disposal and destruction protocols for protected health information (PHI), ensuring they meet or exceed HIPAA and state medical information act standards; (2) hazardous and medical waste handling specifications, requiring compliance with California Hazardous Waste Control Law and Medical Waste Management Act; (3) audit rights and inspection provisions to verify contractor practices; (4) indemnification and insurance requirements for regulatory violations; and (5) mandatory training and certification clauses for personnel handling sensitive materials. Agreements may need amendments to mandate third-party audits, stricter dumpster security protocols, and immediate breach notification procedures for any discovered improper disposal.

Contract Search Terms

medical waste management agreementprotected health information disposal proceduresHIPAA business associate agreementhazardous waste handling clausedata retention and destruction schedulevendor compliance certificationaudit rights for waste disposalconfidentiality of medical information addendumenvironmental compliance warrantyindemnification for regulatory violations

Laws Cited

California Hazardous Waste Control LawCalifornia Medical Waste Management ActCalifornia Confidentiality of Medical Information ActCalifornia Customer Records LawCalifornia Unfair Competition LawHealth Insurance Portability and Accountability Act (HIPAA)

Violation Types

Entity Details

Entity

Kaiser Foundation Health Plan, Inc. and Kaiser Foundation Hospitals

Also known as: Kaiser

Industry

Healthcare

Official Sources

Related Enforcement Actions

CA

Paramount Skydance Corporation

A coalition of 12 state attorneys general, led by Colorado AG Phil Weiser, obtained a temporary restraining order from a federal court in California to halt the proposed $110 billion merger of Warner Bros. Discovery, Inc. by Paramount Skydance Corporation. The lawsuit alleges the merger violates Section 7 of the Clayton Act by substantially lessening competition in film distribution, anticipated blockbuster film distribution, and licensing cable TV channels.

CA

California Privacy Protection Agency

The California Privacy Protection Agency (CalPrivacy) joined a coalition of 18 Attorneys General and state agencies in opposing the proposed SECURE Data Act, a federal privacy bill that would preempt stronger state privacy laws like the CCPA. The coalition argues the bill would weaken consumer privacy protections, limit enforcement remedies, and undermine California's Delete Request and Opt-out Platform (DROP).

CA

General Motors

$12.8M

California Attorney General Rob Bonta, along with multiple district attorneys and the California Privacy Protection Agency, announced a $12.75 million settlement with General Motors for illegally selling hundreds of thousands of Californians' location and driving data to data brokers Verisk and LexisNexis without notice or consent. The settlement includes the largest CCPA penalty to date, a five-year ban on selling driving data to consumer reporting agencies, and requirements to delete retained data and implement a robust privacy program.

CA

California Privacy Protection Agency

The California Privacy Protection Agency Board voted to support two bills (AB 1542 and SB 1106) and took a 'support if amended' position on a third bill (AB 883). These bills aim to strengthen privacy protections by expanding sensitive data protections, improving deletion rights under the Delete Act, and providing expedited deletion for elected officials and judges.

CA

California Privacy Protection Agency

The California Privacy Protection Agency sent a letter to Congress opposing the SECURE Data Act, a federal bill that would preempt state privacy laws like the CCPA and Delete Act. The letter argues the bill would eliminate rights for 40 million Californians, including the DROP platform and opt-out preference signal requirements, and urges Congress to set a floor rather than a ceiling on privacy protections.

CA

Nexstar Media Group, Inc. and Tegna Inc.

California Attorney General Rob Bonta, joined by attorneys general from seven other states, filed a lawsuit to block the $6.2 billion merger between Nexstar Media Group and Tegna Inc. The lawsuit alleges the merger violates Section 7 of the Clayton Act by reducing competition in local TV markets, leading to higher prices, less local news, and job losses.