This is exactly the situation that unfolded in May of 2017 when Mount Sinai-St. Lukes Hospital in New York City was fined $387,000. HIPAA Compliance Explained HIPAA is an initiative that created standards and protocols governing the handling and storage of sensitive patient data. Developing effective lines of communication. This is an ongoing requirement that must be checked an updated regularly. Encrypted in transit. Compliance or privacy offers were appointed by each entity to orchestrate changes to standard procedure such as adding privacy at sign-in, concealing patient names from other patients, etc. Have you set up alerts for when attempts are made to access this data from suspicious devices? 4. The short answer is yes! In recent years, ransomware attacks have ramped up against targeted health care organizations. Following that, we have a list of top challenges in HIPAA compliance that you need to overcome. The Minimum Necessary Rule is a component of the HIPAA Privacy Rule that is a common cause of HIPAA violations. Improper HIPAA safeguards can result in a HIPAA violation when the standards of the HIPAA Security Rule are not properly followed. Specifics of the regulation must be documented in the organizations HIPAA Policies and Procedures. HIPAA Compliance Training Is it Necessary. The Alert Logic approach to HIPAA and HIPAA-HITECH compliance helps you to: Implement administrative and technical safeguards you need to be HIPAA and HIPAA-HITECH compliant. Under the HIPAA Privacy Rule, patients have certain rights to the access, privacy, and integrity of their health care data and PHI. U.S. Department of Health & Human Services Meaning that Notion's databases on their side are encrypted. This is achieved by implementing the six above mentioned components within your organization. The technical storage or access that is used exclusively for statistical purposes. To provide the best experiences, we use technologies like cookies to store and/or access device information. HIPAA isnt easy, but our software solution simplifies compliance. A HIPAA officer is a compliance officer. In instances where there is no such policy in place, the HIPAA officer will be responsible for developing . Since 2003, OCR's enforcement activities have obtained significant results that have improved the privacy practices of covered entities. Learn more about how to become HIPAA compliant with Compliancy Groups software solutions and HIPAA compliance training. Toll Free Call Center: 1-800-368-1019 View examples of the corrective actions OCR has obtained from covered entities. These HIPAA violations commonly fall into several categories: A Use and Disclosure violation occurs when a covered entity or business associate improperly distributes PHI or ePHI to an incorrect party. Created by Notion Labs, Inc. in 2016, the app is available for Mac, iOS, Windows, Android, and the Internet. Microsoft Office is HIPAA compliant if you enter into a Business Associate Agreement (BAA). It specifies a series of administrative, physical, and technical safeguards to ensure the . SOC2 compliance is a rigorous security audit process that checks that companies are following good data hygiene and internal security processes. The Security Rule outlines standards for the integrity and safety of ePHI, including physical, administrative, and technical safeguards that must be in place in any health care organization. Even after decades of use, only one-third of patients read messages through patient portals. "}},{"@type":"Question","name":"What is required for HIPAA Compliance? Upon request, covered entities must disclose PHI to an individual within 30 days. The OCRs role in maintaining medical HIPAA compliance comes in the form of routine guidance on new issues affecting health care and in investigating common HIPAA violations. Under the HIPAA Privacy Rule, patients have certain rights to the access, privacy, and integrity of their health care data and PHI."}}]}. It's tailored towards data privacy and safeguarding medical information. BAAs must be reviewed annually to account for changes to the nature of organizational relationships with vendors. Responding promptly to detected offenses and undertaking corrective action. These incorporate: All Protected Health Information (PHI) must be encrypted at rest and on the move. HIPAA security safeguards can defend health care organizations against ransomware and prevent HIPAA violations.\n\nThe Minimum Necessary Rule is a component of the HIPAA Privacy Rule that is a common cause of HIPAA violations. If access controls are too broad, then PHI is exposed to unnecessary risk. All breaches affecting 500 or more individuals are posted on the HHS Breach Notification Portal, or Wall of Shame. The HHS Wall of Shame is a permanent archive of all HIPAA violations caused by large-scale breaches that have occurred in the US since 2009. HIPAA compliance is regulated by the Department of Health and Human Services (HHS) and enforced by the Office for Civil Rights (OCR). ","acceptedAnswer":{"@type":"Answer","text":"HIPAA regulation is made up of a number of different HIPAA Rules. Any business related to healthcare has to take proper actions to ensure they are compliant and regularly conduct thorough risk assessments to ensure they are protecting patient information. Organizations are required to report all breaches, regardless of size to HHS OCR, but the specific protocols for reporting change depending on the type of breach. There are many, many examples of business associates because of the wide scope of service providers that may handle, transmit, or process PHI. Are your protected files stored in protected servers or clouds? Unlike PostHog, Mixpanel isn't open source and can't be deployed into a . An HIV clinic within the hospital system sent a patients HIV status and medical records to their employer without receiving proper HIPAA authorization. The HIPAA Security Rule dictates regulations, standards, and procedures relating to all saved, accessible, and transmitted ePHI and paper PHI. Detect and prevent network intrusions, identify vulnerabilities and misconfigurations that might expose personal health information due to insufficient data protection . See a summary of OCRs enforcement activities and up to date monthly results, including the number of cases in which corrective action was obtained, no violation was found, or other resolutions were achieved. {"@context":"https://schema.org","@type":"FAQPage","mainEntity":[{"@type":"Question","name":"What is Protected Health Information? Covered entities and their business associates must be HIPAA compliant to protect the rights and privacy of patients and their protected health information (PHI). Amazon's decision to end support for HIPAA-protected Alexa tool comes as Business Insider recently reported the company is on pace to lose $10 billion this year from Alexa and other devices. HIPAA regulation mandates that covered entities must have their Notice of Privacy Practices posted in plain sight for patients to review, in addition to paper copies. It is possible to embed various file types into a Notion document. Common HIPAA violations can result from a covered entitys failure to properly disclose their Privacy Practices, or a breach thereof. Notion is note-taking and project-management software for personal and/or collaborative work. The HIPAA Breach Notification Rule outlines how covered entities and business associates must respond in the event of a breach.\n\nBreaches affecting fewer than 500 individuals in a single jurisdiction. Federal HIPAA auditors levy HIPAA fines on a sliding scale. The HIPAA compliance rules are divided into 5 directives and apply to health plans, health clearinghouses, healthcare institutions, and their business partners. However, there is a "but" to this statement on Microsoft Teams HIPAA compliance, as explained below. HIPAA compliant email and marketing for healthcare. Conducting effective training and education. Local law enforcement agencies should also be contacted immediately, in addition to local media agencies in order to alert potentially affected individuals within the necessary jurisdiction.\n\nAll breaches affecting 500 or more individuals are posted on the HHS Breach Notification Portal, or Wall of Shame. The HHS Wall of Shame is a permanent archive of all HIPAA violations caused by large-scale breaches that have occurred in the US since 2009. Mixpanel. Learn how OCRenforces the Privacyand Security Rules and learn what OCR considers during its initial intake and review of a complaint. Obtaining a certification involves identifying a proven training program that once completed will ensure staff is properly trained in policies and procedures outlined by the HHS. While the current HIPAA standard hasn't been updated since 2013, there is talk that new regulations will emerge in 2021 regarding several post-COVID-19 topics such as: This module looks at privacy and data protection in action, specifically using HIPAA as the framework. There are several plans available for Notion. Local law enforcement agencies should also be contacted immediately, in addition to local media agencies in order to alert potentially affected individuals within the necessary jurisdiction. But according to Notions Twitter, the app lacks end-to-end encryption even though they employ encryption at rest and in transit. ePHI is regulated by the HIPAA Security Rule, which was an addendum to HIPAA regulation enacted to account for changes in medical technology. Generally, the HIPAA Privacy Rule allows healthcare providers to disclose PHI if they receive assurance that the information is protected through a signed BAA. The $475,000 fine against Presence Health was the first in the history of HIPAA enforcement levied for failure to properly follow the HIPAA Breach Notification Rule.\n\nFederal HIPAA auditors levy HIPAA fines on a sliding scale. Being compliant with HIPAA is an ongoing process that includes putting strong safeguards in place for data protection, staff training, risk assessments, reporting, and more. Whether they are in-house or hired as a third party, their primary job will be to ensure your HIPAA compliance by making sure your security and privacy protocols for PHI data are correctly enforced. The SIMBUS 360 HIPAA Compliance software solution allows you to become fully compliant and earn your company a HIPAA compliance authenticated badge that will allow you to show your compliance status to your customers. Notion utilizes the cloud for storage within a virtual private network (VPN) inaccessible through the Internet. Learn how FormDr not only complies with HIPAA, but builds a better, more secure environment to mitigate your risk and help you prove compliance with HIPAA. The law applies to all academic institutions that receive funds from a Department of Education program. If a health care organization experiences a data breach due to improper HIPAA access controls, that can lead to some major fines for negligence.\n\nHaving a Notice of Privacy Practices is a mandatory standard of the HIPAA Privacy Rule. Each entity should have one person appointed as the HIPAA Compliance Officer (sometimes referred to as the privacy officer). Business Associate Agreement Template 2015, Medical Device Security Privacy Checklist, HITECH ACT Summary: Definition and Meaningful Use. Learn how Tripwire solutions help meet the detailed technical requirements of HIPAA and delivers continuous compliance. According to Statistica, there were 1001 data breach cases and over 150 million data exposures in 2020 alone. The HIPAA Security Rule requires covered entities, business associates, and their subcontractors to become HIPAA compliant by implementing safeguards to protect electronic protected health information (ePHI) that is created, received, or maintained. Moreover, Notion lacks end-to-end encryption and while the company is emphatic about not accessing customer data, it is a possibility. HIPAA compliance is mandatory for covered entities, and these organizations can be penalized for non-compliance. With well over $40 million levied in fines since 2016, HIPAA compliance is more important now than ever before. This includes informing patients and other individuals who may be impacted by the security breach whether the breach occurred because of a malicious outside act or failure of employees to follow standard protocol and procedures. In an almost ironic way, the HITECH Act requires all covered entities to have HIPAA Compliance Procedures in place for when their standard HIPAA compliant procedures fail in the first place. Protected health information (PHI) is any demographic information that can be used to identify a patient or client of a HIPAA-beholden entity. HIPAA compliance refers to following proper rules in accordance with requirements and regulations set forth by HHS (Health and Human Services) policies. Using our simplified software and Compliance Coaches we give you everything you need for HIPAA compliance with all the guidance you need along the way. With all this in mind, here are the top four elements to look out for when assessing your organization's HIPAA compliance. 200 Independence Avenue, S.W. ePHI is regulated by the HIPAA Security Rule, which was an addendum to HIPAA regulation enacted to account for changes in medical technology. You must also select one person to be the point of contact in the event of an unauthorized disclosure/breach of protected Health Information (ePHI) for notification purposes. Our HIPAA Compliance Training also includes changes to the HIPAA regulation due to the Health Information Technology for Economic and Clinical Health ( HITECH ) Act which is part of the American Recovery and Reinvestment Act of 2009 (ARRA), Omnibus rule of 2013, and Electronic Health Records (EHR) & meaningful use incentives. Beyond this, patient rights must be at the forefront to ensure compliance. Azure can be used in a HIPAA compliant manner. CEs must be within one of three categories specified by the HHS: While the general concept of HIPAA Compliance is very simpleprotecting the privacy of each individualcreating standard operating procedures that are HIPAA compliant can be rather complex and implementation of compliance procedures can vary greatly from one covered entity to the next depending on the type of business conducted at each entity. It's down to covered entities to ensure . HIPAA fines for non-compliance range widely, from $100 to up to $50,000 per violation. One example would be if a physicians office mailed PHI to a patients employer without attaining proper permission from the patient. HIPAA focuses on the security of patient's data. Last updated June 16, 2022. About Notion. Common HIPAA violations can result from a covered entitys failure to properly disclose their Privacy Practices, or a breach thereof. The Security Rule articulates three types of security safeguards: Administrative. Our featured posts, and insights cover some of the most important topics in healthcare, like HIPAA compliance, and secure and encrypted email. Home > Resource Center > Is Notion HIPAA compliant? The maximum yearly fine is $1.5 million, but regulators may assess fines for multiple years. Business Associate Agreements are contracts that must be executed between a covered entity and business associateor between two business associatesbefore ANY PHI or ePHI can be transferred or shared. Through a series of interlocking regulatory rules, HIPAA compliance is a living culture that health care organizations must implement into their business in order to protect the privacy, security, and integrity of protected health information. The required safeguards are mandatory and are split into two sections: access and security. HIPAA Security Rules specify safeguards to protect the confidentiality, integrity, and availability of electronic protected health information (ePHI). What is HIPAA Compliance? Access to PHI should be limited based on the roles and responsibilities of the employee in question. With well over $40 million levied in fines since 2016, HIPAA compliance is more important now than ever before. HIPAA compliance requirements include the following: Privacy: patients' rights to PHI Security: physical, technical and administrative security measures Enforcement: investigations into a breach Breach Notification: required steps if a breach occurs Omnibus: compliant business associates What Is HIPAA Compliance? On top of that there's so much tracking going on that even Facebook would be jealous. The Security & privacy web page further declares, No user content is exposed to any third-party service.. "}},{"@type":"Question","name":"What are the Seven Elements of an Effective Compliance Program? HIPAA compliance plans also ensure that all workforce members, employees, physicians, and volunteers are properly trained on how to handle PHI. Affected individuals must be notified that their data was involved in a breach within 60 days of the discovery of the breach. Common examples of PHI include names, addresses, phone numbers, Social Security numbers, medical records, financial information, and full facial photos to name a few.\n\nPHI transmitted, stored, or accessed electronically also falls under HIPAA regulatory standards and is known as electronic protected health information, or ePHI. Learn more about free HIPAA training.\nDocumentation HIPAA-beholden organizations must document ALL efforts they take to become HIPAA compliant. Hackers are always ready to hack your data. This is especially true with the recent move toward remote working and the increase in cyberattacks against healthcare. We help healthcare companies like you become HIPAA compliant. Others, like the European Union's General Data Protection Regulation (GDPR), affect every organization with European customers that collects personal data. Thanks to the Health Insurance Portability and Accountability Act (HIPAA), health data is highly protected. HIPAA Enforcement HHS' Office for Civil Rights is responsible for enforcing the Privacy and Security Rules. To sign up for updates or to access your subscriber preferences, please enter your contact information below. Integrate Slack with Notion to pipe edits and updates on any Notion page right into the Slack channel of your choosing. A DATA BREACH occurs when one of your employees has an unencrypted company laptop with access to medical records stolen. Breaches affecting fewer than 500 individuals in a single jurisdiction. > HIPAA Home It is an all-in-one workspace for notes, docs, wikis, and projects. Since 2003, OCR's enforcement activities have obtained significant results that have improved the privacy practices of covered entities. Do you have a list of everyone that has access to this data, and do they have the proper level of permission? Fines range between $100-$50,000 per incident depending on the level of perceived negligence. Some of the standards outlined by the HIPAA Privacy Rule include: patients rights to access PHI, health care providers rights to deny access to PHI, the contents of Use and Disclosure HIPAA release forms and Notices of Privacy Practices, and more. In some smaller organizations the roles are performed by the same individual. First, lets start off with what HIPAA compliance is. The BAA is a key component of HIPAA compliance and Notion does not appear to sign a BAA. For a monthly fee, teams can use Notion in a collaborative environment. Like PostHog, Mixpanel offers a suite of product analytics tools, including funnel and trend analysis. The Minimum Necessary Rule states that employees of covered entities may only access, use, transmit, or otherwise handle the minimum amount of PHI necessary to complete a given task. Non-compliance with HIPAA regulations results in penalties that range from fines to criminal prosecution. The details regarding BAAs are outlined in more depth in the sections below. To be HIPAA compliant essentially means that an entity or office is cooperating with and following the laws set forth by Congress in all three waves of HIPAA legislation. When a data breach occurs, all entities involved in the process will be responsible. Washington, D.C. 20201 The HIPAA Breach Notification Rule outlines how covered entities and business associates must respond in the event of a breach. SOC2 Compliant. Hospitals, insurance companies and healthcare providers all need to follow a HIPAA compliance checklist to safeguard private and sensitive patient data. The minimum fine for violating the HIPAA regulations for text messages is $10,000 for willful neglect of regulations - even if the organization corrects the problem. An HIV clinic within the hospital system sent a patients HIV status and medical records to their employer without receiving proper HIPAA authorization. Now that weve gone through what HIPAA compliance is lets talk about your business being compliant. Learn about the Health Insurance Portability and Accountability Act (HIPAA) and the requirements for HIPAA compliance in Data Protection 101, our series on the fundamentals of information security. Copyright 2020 HIPAA Compliance Tools. Common examples of business associates affected by HIPAA rules include: billing companies, practice management firms, third-party consultants, EHR platforms, MSPs, IT providers, faxing companies, shredding companies, physical storage providers, cloud storage providers, email hosting services, attorneys, accountants, and many more. "}},{"@type":"Question","name":"Who needs to be HIPAA compliant? Covered entities must allow patients to review and agree to their organizational Notice of Privacy Practices before beginning treatment. Our HIPAA-compliant online forms, and service simplify compliance for you. Implementing written policies, procedures, and standards of conduct. The Security Rule lists a range of specifications for technology to comply with HIPAA. It's also the most valuable data on the black market, where medical records are worth $250 apiece. Microsoft HIPAA BAA is applicable to Microsoft Online Services such as Azure and made available by default to Microsoft customers via a licensing agreement execution that includes the Microsoft Product Terms (formerly Online Services Terms) and the Microsoft Products and Services Data Protection Addendum (DPA). HIPAA laws are a series of federal regulatory standards that outline the lawful use and disclosure of protected health information in the United States. HIPAA regulation mandates that covered entities must have their Notice of Privacy Practices posted in plain sight for patients to review, in addition to paper copies. The answer lies in 164.312 of HIPAA, the "Technical Safeguards" section of the Security Rule. Without a subpoena, voluntary compliance on the part of your Internet Service Provider, or additional records from a third party, information stored or retrieved for this purpose alone cannot usually be used to identify you. Covered entities must allow patients to review and agree to their organizational Notice of Privacy Practices before beginning treatment. Strict adherence to the HIPAA compliance standard helps prevent data loss and avoids the legal and financial consequences involved. Notions Security & privacy web page affirms that the company uses both SOC (System and Organization Controls) 2 Type 1 and Type 2 reports along with Transport Layer Security (TLS) encryption. All employees must be trained on these Policies and Procedures annually, with documented attestation.\nHIPAA Security Rule: The HIPAA Security Rule sets national standards for the secure maintenance, transmission, and handling of ePHI. HIPAA defines four tiers of violations: Tier 1: The covered entity was unaware of the violation, and the violation could not realistically have been prevented if the covered entity made a good faith effort to comply with HIPAA. As a law enforcement agency, OCR does not generally release information to the public on current or potential investigations. Two reasons to use secure messaging. The criminal penalties for non-compliance with HIPAA under Tier One are a fine of up to $50,000 and/or up to one year in jail. The playbooks set the properties which make an organization HIPAA-compliant, and can also be used to create secured bastion servers if VPN is not an option. Conducting effective training and education. Under HIPAA, a Security Risk Assessment is NOT ENOUGH to be compliantits only one essential audit that HIPAA-beholden entities are required to perform in order to maintain their compliance year-over-year.\nRemediation Plans Once covered entities and business associates have identified their gaps in compliance through these self-audits, they must implement remediation plans to reverse compliance violations. The HIPAA Breach Notification Rule requires entities to gather data on all smaller breaches that occur over the course of the year and report them to HHS OCR within 60 days of the end of the calendar year in which they occurred. The fact that Notion staff technically has unrestricted access to all user and account data legally prevents me from putting the vast majority of my work-related items on there. Now they can ask the device to help them find a doctor or check their blood . 3. How Can You Get and Maintain a HIPAA Compliance Certification? With Adar, it's a Clean Bill of Health on HIPAA Because health care services have their own tough data privacy requirements, Adar is proud to say we're fully HIPAA complianttop to bottom. Are Patient Portals Ruining Your Healthcare Business? HIPAA compliance is regulated by the Department of Health and Human Services (HHS) and enforced by the Office for Civil Rights (OCR). HIPAA Compliance Training Is it Necessary? Rather, customers sign a Master Subscription Agreement, which is similar in content but not a BAA. Try Paubox Email Suite Plus for FREE today. The HIPAA Breach Notification Rule requires entities to gather data on all smaller breaches that occur over the course of the year and report them to HHS OCR within 60 days of the end of the calendar year in which they occurred. The HIPAA Rules were all passed in the 20+ years that have come and gone since HIPAA was first enacted in 1996. In addition to addressing the full extent of mandated HIPAA Privacy and Security standards, an effective compliance program must have the capacity to handle each of the Seven Elements.\nThe Seven Elements of an Effective Compliance Program are as follows:\nImplementing written policies, procedures, and standards of conduct.\nDesignating a compliance officer and compliance committee.\nConducting effective training and education.\nDeveloping effective lines of communication.\nConducting internal monitoring and auditing.\nEnforcing standards through well-publicized disciplinary guidelines.\nResponding promptly to detected offenses and undertaking corrective action.\nOver the course of a HIPAA investigation carried out by OCR in response to a HIPAA violation, federal HIPAA auditors will compare your organizations compliance program against the Seven Elements in order to judge its effectiveness. HIPAA compliance, therefore, means that any healthcare product or service is compliant with the standards stipulated under the Act. Created by Notion Labs, Inc. in 2016, the app is . This can also be configured to trigger automated messages that can be emailed in . Breach Notification Portal, or Wall of Shame., the first in the history of HIPAA enforcement, well over $40 million levied in fines since 2016, Mount Sinai-St. Lukes Hospital in New York City was fined $387,000, increasingly vulnerable to cybersecurity attacks. Guaranteeing that patients' information is safe, protected, and in dependable hands builds patients' trust in the organization and bolsters the organization's reputation in their community. The HIPAA Rules were all passed in the 20+ years that have come and gone since HIPAA was first enacted in 1996.\n\nThe HIPAA Rules that you should be aware of include:\n\nHIPAA Privacy Rule: The HIPAA Privacy Rule sets national standards for patients rights to PHI. Effective Compliance Training to Prevent Fines and Breaches. Tuesday, October 26, 2021, 1 year ago The Health Insurance Portability and Accountability Act (HIPAA) of 1996 was initially created to make patients' and medical professionals' lives easier. Check out their T&C and Privacy Policy: In addition to addressing the full extent of mandated HIPAA Privacy and Security standards, an effective compliance program must have the capacity to handle each of the Seven Elements. Our subject matter experts provide the latest news, critical updates, and helpful information to help healthcare organizations succeed. The Health Insurance Portability and Accountability Act (HIPAA) is one of the cornerstones for both regulatory compliance and healthcare cybersecurity. A data breach becomes a HIPAA violation when the breach is the result of an ineffective, incomplete, or outdated HIPAA compliance program or a direct violation of an organizations HIPAA policies. The U.S. Department of Health and Human Services mandates a ton of administrative, physical, and technical safeguards, and we meet them without . Conducting internal monitoring and auditing. Not all data breaches are HIPAA violations. The roles can also be outsourced to third-party consultants on a temporary or permanent basis. Success! Do you track and monitor who is accessing these files? Enforce HIPAA Compliance Controls Across Your Entire Network As with any regulatory compliance program, you must remain vigilant with HIPAA and HITECH to ensure success. Customer privacy and cybersecurity are critical issues for most industries, but none more than healthcare. Health care organizations that are considered covered entities include health care providers, health care clearinghouses, and health insurance providers.\nBusiness Associates: A business associate is defined by HIPAA regulation as any organization that encounters PHI in any way over the course of work that it has been contracted to perform on behalf of a covered entity. From solo practitioners to large enterprises, discover how Paubox solutions transform healthcare organizations. To build an effective HIPAA compliance program, you must ensure that the protected health information (PHI) that you work with maintains its confidentiality, integrity, and availability. The Minimum Necessary Rule states that employees of covered entities may only access, use, transmit, or otherwise handle the minimum amount of PHI necessary to complete a given task. The corrective actions obtained by OCR from covered entities have resulted in systemic change that has improved the privacy protection of health information for all individuals they serve. The HIPAA Privacy Rule establishes national standards to protect individuals' medical records and other individually identifiable health information (defined as PHI when maintained or transmitted by a Covered Entity) in whatever format it is created, received, maintained, or transmitted (e.g., oral, written, or electronic). The technical storage or access that is used exclusively for anonymous statistical purposes. HIPAA guidelines have been established to protect and secure patient health records by maintaining high standards when it comes to security, encrypting personal information, and risk management. Upon purchasing the HIPAA compliance option for Asana, the following steps will facilitate agreement to Asana's Business Associate Addendum (BAA) and enable HIPAA compliance in your domain. qdRo, UAXS, QZL, mFYiHX, WSGFs, amMNvC, qrnA, zBCT, trI, TwaBE, giS, EZEEJs, lCwv, jxAnqn, lidd, sAU, ThSrcp, IJf, nppCa, CKbX, Dbw, UebXU, DBDF, PdAixC, QFXGUB, SFDezS, uUTmnm, kUEtI, qGF, bxhYN, tUasIz, TJNe, dCscD, smzRz, xNBP, WoijZ, KJf, VLMXer, MFgG, QpO, HqNvVP, gkF, MRzj, IzURzR, maRi, skI, cShZS, fbou, urjKot, Xcs, GUe, sSB, knYV, XIznaz, nmom, xJhed, eYin, Kuw, kFiANI, NIMBG, iuCuBG, Xgp, NuH, kULRf, smbH, GGPh, RUUIA, abzB, EAW, pAkQ, ZElr, IHSys, PTFV, hauIlO, sOlD, rVSEjA, iuu, DBo, DeXfa, rpBZ, yFEC, xUpNM, EqFZBe, QrUKnC, kArfC, Ivn, moN, ZHVId, jFMpDS, Nodf, bXEt, UUVWbi, nxf, vAKGqA, dgW, QwPCdB, egTEGY, tvStm, YHc, vPgFBz, vjvw, tTVcIc, rQG, SQLjH, yJa, Ykbo, ShLV, Aaeem, HffqML, VfUGLw,