Because of the $1 million fine that Massachusetts General paid for the "million dollar subway ride," in which a worker took protected health information ("PHI") home to work on and left it on the subway, other hefty fines for the loss of electronic protected health information ("EPHI"), such as on laptops, and the fact that the single biggest category of breaches reported to the Department of Health and Human Services ("DHHS") under the HITECH Act's requirement to report breaches of...