The HITECH Act authorizes a state attorney general to bring a civil action for an injunction or damages in situations where the attorney general “has reason to believe that an interest of one or more of the residents of that State has been or is threatened or adversely affected” by a HIPAA violation.  The HHS Office for Civil Rights has initiated a series of HIPAA enforcement training courses for state attorneys general.  The first was held in Dallas in April.  Sessions are planned for each of Atlanta and Washington, D.C., in May and for San Francisco in June.  More information about the sessions (which are open only to state attorneys general and their staffs) on the OCR website.  These sessions may serve as an impetus for state enforcement actions.  Hopefully, the sessions will also serve to provide some level of uniformity in interpretation of HIPAA obligations by state attorneys general.