Those who practice in Wake, Johnston, Harnett and Lee counties have already begun to experience what it is like to perform a search in the Odyssey Portal system. It is sad to report that the AOC legacy system VCAP has more robust searching logic than the new Odyssey system.
AOC is aware of the problems with the search functionality. See attached Notes from the February 27, 2023 AOC Meeting. The notes lay out many of the reported examples regarding problems with the searching features. The four counties are called “Pilot” counties because the kinks in the system are being worked out before the system rolls out. AOC is actively working with Tyler Technologies to strengthen and change the search logic based on reported issues.
There is no clear timetable as to when the better-performing features will be developed and implemented. Changes and updates are happening in response to known issues without announcement as this system is a work in progress. For those using the current iteration of the Pilot Odyssey system, some of the known pitfalls and tricks are laid out herein and in the attached notes from the AOC meeting. As new features become available, the Real Property Section will continue to send out the pertinent information.
https://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.png00RealPropertyhttps://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.pngRealProperty2023-03-21 14:24:252023-03-21 14:24:25Odyssey Pilots in Wake, Johnston, Harnett & Lee Counties: A Real Property Perspective
Candace Friel finds her passion for pro bono work in projects where she gets to work with clients one-on-one, especially at home in the Triad. Friel is a partner at Nelson Mullins Riley & Scarborough, working as a healthcare and commercial litigator, and she is a member of the NCBA’s Health Law Section.
Since beginning her legal career at Nelson Mullins in 2007, Friel has built a robust pro bono practice, volunteering with driver’s license restoration clinics, Rebuild North Carolina, A Gift to Your Family advanced directive clinics, and more. Friel appreciates the opportunity to work with pro bono clients in person like she did with Rebuild North Carolina, where her client was seeking funds to help rebuild after Hurricanes Florence and Matthew.
Now that the 2023 legislative session is underway, numerous House and Senate committees are meeting to discuss current legislation along with studies and issues of concern by members of the public, state agencies, and trade groups. One such committee, the House Committee on Regulatory Reform (“HCRR”), is of particular interest to this section. The HCRR met on Wednesday, March 15, and invited the John Locke Foundation along with the Rules Review Commission to give presentations to its committee members.
Jon Sanders, on behalf of the John Locke Foundation, gave a presentation entitled “Occupational Licensing.” Sanders started his presentation off by noting that the North Carolina Constitution states that “enjoyment of the fruits of their own labor” is among a North Carolina citizen’s inalienable rights. He went on to say that occupational licensing is an “entry barrier to someone seeking work in a desired field” and that licensing is North Carolina’s most restrictive occupational regulation, which should be used only when risk to the public welfare is highest. Sanders noted that the North Carolina Department of Commerce’s database shows 931 licenses, which include privilege licenses and special events permitting. He went on to discuss the benefits of licensure (i.e., to protect health, safety and welfare) along with the costs (i.e, fees and background checks). Sanders explained that these regulations result in higher prices for licensed work, fewer options, and poor or dangerous alternatives. He went on to state that these regulations also result in limited growth in licensed occupations, less competition, fewer economic opportunities and less wealth creation. Sanders did not cite any resources or data for these conclusions. Sanders suggested to reserve occupational licensing only for a significant public harm and to instead explore certification, registration, bonding/insurance, inspections, and stronger laws for consumer protections to combat other public harm. Finally, Sanders suggested that the legislative members consider other reforms such as Universal License Recognition, which has been passed in 19 states, along with an Occupational Licensing Consumer Choice Act. The latter would allow unlicensed persons to provide a non-license disclosure form to consumers, which would show their lack of licensure, but would list their other training, experience, or certifications. Sanders stated that consumers would be able to sue the “bad actors” for redress in court and could leave bad reviews for them, which would warn other consumers. He also welcomed people in that industry to call out the bad actors in their profession through advertising.
Lucy Inman has joined the firm’s Raleigh office. She will focus on appellate cases. Inman earned a B.A. in English from North Carolina State University in 1984, and after obtaining her undergraduate degree, she became a newspaper reporter. Inman graduated with honors from The University of North Carolina School of Law in 1990. While in law school, she was an articles editor for The North Carolina Law Review. She clerked for Chief Justice Exum in the North Carolina Supreme Court.
Inman has extensive civil litigation experience, an area in which she practiced for 18 years, first in Los Angeles and in Raleigh. For more than twelve years, she was a trial and appellate judge in North Carolina. She served as a Superior Court judge in North Carolina from 2010 to 2014. Inman won statewide election to the North Carolina Court of Appeals and served in this capacity from 2015 to 2022. She authored more than 450 appellate opinions.
Inman is a member of the Judicial Independence Committee of the National Association of Women Judges. She has previously served in leadership roles with the North Carolina Bar Association and the North Carolina Association of Women Attorneys. She has been a participant in the Judicial Division of the American Bar Association and Appellate Judges Education Institute.
I have been Smith Anderson’s Chief Diversity Officer for over a year now. In this new role for our firm, I have contributed to the impactful Diversity and Inclusion (“D&I”) efforts of our firm’s longstanding D&I Committee and led other new and exciting efforts and projects.
As a Black and Asian woman, I know how it feels to feel “othered” in many spaces throughout my life. This personal experience inspires me to do everything I can to make sure that every individual who works at Smith Anderson feels that they are home and can bring their full authentic selves to work. When people are fully authentic at work, we all benefit from learning from one another and having people with differing backgrounds and perspectives all working towards the same goal.
Some of my favorite D&I efforts at Smith Anderson have been our community building work because it facilitates opportunities for real and authentic connection (beyond the standard elevator conversation about the weather and other small talk). Our efforts include quarterly social events for diverse associates, diversity mentorship programs, and panels with diverse in-house counsel.
We recently put on an event where all mentors and mentees in the diversity mentorship program selected a book that was meaningful to their life and experience. Each person then explained why they chose this book and then the book was given to another participating lawyer for them to read. Copies of all the books were gifted to a local school for future scholars to enjoy. This event was particularly meaningful because it built community and connection within Smith Anderson while also giving back to the Raleigh community in which we live and work.
I’m also proud to lead our firm’s Mansfield Certification efforts. “The goal of the Mansfield Rule is to boost the representation of diverse lawyers in law firm leadership by broadening the pool of candidates considered for these opportunities.” In participating in Mansfield Certification, we have had the opportunity to exchange ideas about D&I efforts with our fellow Mansfield cohort and to make sure that we are considering our diverse attorneys for key opportunities and positions within our firm.
My most cherished parts about being the Chief Diversity Officer are the open and honest conversations that I have with my co-workers about ideas for new D&I efforts, their lived experiences, and their paths to becoming a lawyer. Through these open and vulnerable conversations, I learn so much from them and can incorporate their feedback into new efforts or changes to our existing efforts. We have to be able to adapt and tailor our efforts to the needs of our internal community, and having these conversations allows us to do just that.
I cannot wait to build upon my experience from the first full year to create even more impact for 2023!
https://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.png00NCBA YLDhttps://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.pngNCBA YLD2023-03-20 14:41:302023-03-20 14:58:19Your Authentic Self is an Asset to Your Office
Please join your health law colleagues around the state for the NCBA Health Law Section’s annual CLE program, Friday, April 21, 2023. This year’s program – “Keeping a Finger on the Pulse” – will be offered in person at the North Carolina Bar Center in Cary and via live Webcast! You can receive up to 6.25 total CLE credits, including 1.0 hour of Ethics/Professional Responsibility credit. Generous sponsorships have enabled the section to offer this full day of CLE and networking opportunities to section members for only $225 (even less for students, law professors, judges and public interest lawyers).
This year’s program will include several hours of North Carolina specific healthcare content, including a Keynote presentation from Jay Ludlam, Assistant Secretary of the North Carolina Department of Health and Human Services, who will address the current health care landscape in North Carolina, including challenges navigating the post-pandemic environment and the North Carolina Medicaid program’s transformation from fee-for-service to a managed care delivery system.
The program will also provide networking opportunities including a continental breakfast, lunch and reception following the program. Make plans now and clear your schedule to attend this year’s exciting program on April 21. Registration is open now!
https://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.png00HealthLawhttps://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.pngHealthLaw2023-03-16 11:03:522023-03-16 11:03:52Join Us for the 2023 Health Law Section Annual CLE Program
Section 6104(d)(1)(B) provides a right to taxpayers to request the application for tax exemption and annual informational returns for the last three years of any organization described in Section 501(c) or (d) and exempt from taxation under Sections 501(a) or 527(a). That covers both public charities and private foundations exempt under Section 501(c)(3), as well as other types of tax-exempt organizations.
Reg. § 301.6104(d)-1(d)(2) provides such tax-exempt entities must honor a written request for the documents required to be provided under Section 6104(d) provided the request (a) is addressed to, and delivered by mail, electronic mail, facsimile, or provide delivery service to a principal, regional, or district office of the organization, and (b) sets forth the address to which the copy of the documents should be sent. The charity, pursuant to Reg. § 301.6104(d)-1(d)(3), may require a reasonable fee for providing such copies. Pursuant to Reg. § 301.6104(d)-1(d)(2)(ii)(A), the charity must send the documents within 30 days of the date it receives the request or, if the charity requires payment in advance for the costs associated, 30 days from the date it receives such payment. If the individual making the request consents, the tax-exempt organization may provide the requested document exclusively by electronic mail.
In 2022, the North Carolina Pro Bono Resource Center (the “PBRC”) launched a statewide voluntary Paralegal Pro Bono Reporting process for the first time. In 2022, 127 paralegals reported performing 1,983 hours of pro bono service throughout the year. Additionally, 13 of those paralegals who reported a combined 1,227 hours were inducted into the inaugural cohort of the North Carolina Paralegal Pro Bono Honor Society! The PBRC has once again opened pro bono reporting for paralegals to report their hours served in 2022. The reporting period closes on March 31, 2023. This process is open to all North Carolina paralegals, regardless of education or certification status.
While there is no requirement for paralegals to offer pro bono services in North Carolina, there is an ethical responsibility for attorneys to do so under North Carolina Rule of Professional Conduct 6.1, and Guideline 10 of the ABA Model Guidelines for Utilization of Paralegal Services states that “[a] lawyer who employs a paralegal should facilitate the paralegal’s participation in appropriate continuing education and pro bono publico activities.” Rule 6.1 encourages North Carolina attorneys to provide at least 50 hours of legal services per year at no cost to individuals of limited means and/or charitable or other organizations that serve individuals of limited means.
https://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.png00Paralegalshttps://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.pngParalegals2023-03-16 10:30:172023-03-16 10:30:172022 Pro Bono Reporting is Open for NC Paralegals
In 2022, the Zoning, Planning and Land Use Section awarded its first scholarships to deserving law students. In order to meet the requirements for the 2022 Scholarship, the recipient must have been an unpaid intern working in a North Carolina government or public interest law department (State, Federal, City or County) who was also enrolled in an American Bar Association accredited law school.
The ZPLU Section is accepting applications for its 2023 scholarship awards – now through April 15.
Last year’s recipients were Ashley Loveless, a 1L from the University of North Carolina School of Law, and Austin Morris, a 1L from Wake Forest University School of Law. By accepting this scholarship, Ashley and Austin agreed to write an essay about their experience as interns. Here is a synopsis of their essays.
https://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.png00ZPLUhttps://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.pngZPLU2023-03-15 15:49:362024-06-06 12:33:09Zoning, Planning & Land Use Section: Student Scholarships
According to a study from January 2016 to December 2021,[1] 374 ransomware attacks on U.S. health care delivery organizations exposed the Protected Health Information (PHI) of nearly 42 million patients. The cybercriminals demand ransom to unencrypt the exfiltrated medical data, and, as such, create a direct threat to public health and safety. In addition, if the facility refuses to pay, some hackers have started posting the sensitive health data on the dark web. Moreover, some of the breached facilities are being sued on behalf of the patients whose data was compromised. Consequently, these recent cyberattacks on health care have significantly increased the cost of cyber insurance. Here are a few examples of recent cyberattacks in health care.
https://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.png00Privacy and Data Securityhttps://ncbarblogprod.wpengine.com/wp-content/uploads/2018/06/Blog-Header-1-1030x530.pngPrivacy and Data Security2023-03-08 11:21:012023-03-08 11:56:41Recent Cyberattacks on Health Care and the Consequences
Odyssey Pilots in Wake, Johnston, Harnett & Lee Counties: A Real Property Perspective
Real PropertyThose who practice in Wake, Johnston, Harnett and Lee counties have already begun to experience what it is like to perform a search in the Odyssey Portal system. It is sad to report that the AOC legacy system VCAP has more robust searching logic than the new Odyssey system.
AOC is aware of the problems with the search functionality. See attached Notes from the February 27, 2023 AOC Meeting. The notes lay out many of the reported examples regarding problems with the searching features. The four counties are called “Pilot” counties because the kinks in the system are being worked out before the system rolls out. AOC is actively working with Tyler Technologies to strengthen and change the search logic based on reported issues.
There is no clear timetable as to when the better-performing features will be developed and implemented. Changes and updates are happening in response to known issues without announcement as this system is a work in progress. For those using the current iteration of the Pilot Odyssey system, some of the known pitfalls and tricks are laid out herein and in the attached notes from the AOC meeting. As new features become available, the Real Property Section will continue to send out the pertinent information.
Read more
Pro Bono Spotlight: Candace Friel
Pro Bono CommitteeCandace Friel
By Allison Standard Constance
Candace Friel finds her passion for pro bono work in projects where she gets to work with clients one-on-one, especially at home in the Triad. Friel is a partner at Nelson Mullins Riley & Scarborough, working as a healthcare and commercial litigator, and she is a member of the NCBA’s Health Law Section.
Since beginning her legal career at Nelson Mullins in 2007, Friel has built a robust pro bono practice, volunteering with driver’s license restoration clinics, Rebuild North Carolina, A Gift to Your Family advanced directive clinics, and more. Friel appreciates the opportunity to work with pro bono clients in person like she did with Rebuild North Carolina, where her client was seeking funds to help rebuild after Hurricanes Florence and Matthew.
Read more
House Committee on Regulatory Reform
Administrative LawNow that the 2023 legislative session is underway, numerous House and Senate committees are meeting to discuss current legislation along with studies and issues of concern by members of the public, state agencies, and trade groups. One such committee, the House Committee on Regulatory Reform (“HCRR”), is of particular interest to this section. The HCRR met on Wednesday, March 15, and invited the John Locke Foundation along with the Rules Review Commission to give presentations to its committee members.
Jon Sanders, on behalf of the John Locke Foundation, gave a presentation entitled “Occupational Licensing.” Sanders started his presentation off by noting that the North Carolina Constitution states that “enjoyment of the fruits of their own labor” is among a North Carolina citizen’s inalienable rights. He went on to say that occupational licensing is an “entry barrier to someone seeking work in a desired field” and that licensing is North Carolina’s most restrictive occupational regulation, which should be used only when risk to the public welfare is highest. Sanders noted that the North Carolina Department of Commerce’s database shows 931 licenses, which include privilege licenses and special events permitting. He went on to discuss the benefits of licensure (i.e., to protect health, safety and welfare) along with the costs (i.e, fees and background checks). Sanders explained that these regulations result in higher prices for licensed work, fewer options, and poor or dangerous alternatives. He went on to state that these regulations also result in limited growth in licensed occupations, less competition, fewer economic opportunities and less wealth creation. Sanders did not cite any resources or data for these conclusions. Sanders suggested to reserve occupational licensing only for a significant public harm and to instead explore certification, registration, bonding/insurance, inspections, and stronger laws for consumer protections to combat other public harm. Finally, Sanders suggested that the legislative members consider other reforms such as Universal License Recognition, which has been passed in 19 states, along with an Occupational Licensing Consumer Choice Act. The latter would allow unlicensed persons to provide a non-license disclosure form to consumers, which would show their lack of licensure, but would list their other training, experience, or certifications. Sanders stated that consumers would be able to sue the “bad actors” for redress in court and could leave bad reviews for them, which would warn other consumers. He also welcomed people in that industry to call out the bad actors in their profession through advertising.
Read more
Checking In: March 21, 2023
Checking InCompiled by Jessica Junqueira
Milberg Coleman Bryson Phillips Grossman, PLLC Welcomes Inman As Senior Counsel
Inman has extensive civil litigation experience, an area in which she practiced for 18 years, first in Los Angeles and in Raleigh. For more than twelve years, she was a trial and appellate judge in North Carolina. She served as a Superior Court judge in North Carolina from 2010 to 2014. Inman won statewide election to the North Carolina Court of Appeals and served in this capacity from 2015 to 2022. She authored more than 450 appellate opinions.
Inman is a member of the Judicial Independence Committee of the National Association of Women Judges. She has previously served in leadership roles with the North Carolina Bar Association and the North Carolina Association of Women Attorneys. She has been a participant in the Judicial Division of the American Bar Association and Appellate Judges Education Institute.
Read more
Your Authentic Self is an Asset to Your Office
Young Lawyers DivisionI have been Smith Anderson’s Chief Diversity Officer for over a year now. In this new role for our firm, I have contributed to the impactful Diversity and Inclusion (“D&I”) efforts of our firm’s longstanding D&I Committee and led other new and exciting efforts and projects.
As a Black and Asian woman, I know how it feels to feel “othered” in many spaces throughout my life. This personal experience inspires me to do everything I can to make sure that every individual who works at Smith Anderson feels that they are home and can bring their full authentic selves to work. When people are fully authentic at work, we all benefit from learning from one another and having people with differing backgrounds and perspectives all working towards the same goal.
Some of my favorite D&I efforts at Smith Anderson have been our community building work because it facilitates opportunities for real and authentic connection (beyond the standard elevator conversation about the weather and other small talk). Our efforts include quarterly social events for diverse associates, diversity mentorship programs, and panels with diverse in-house counsel.
We recently put on an event where all mentors and mentees in the diversity mentorship program selected a book that was meaningful to their life and experience. Each person then explained why they chose this book and then the book was given to another participating lawyer for them to read. Copies of all the books were gifted to a local school for future scholars to enjoy. This event was particularly meaningful because it built community and connection within Smith Anderson while also giving back to the Raleigh community in which we live and work.
I’m also proud to lead our firm’s Mansfield Certification efforts. “The goal of the Mansfield Rule is to boost the representation of diverse lawyers in law firm leadership by broadening the pool of candidates considered for these opportunities.” In participating in Mansfield Certification, we have had the opportunity to exchange ideas about D&I efforts with our fellow Mansfield cohort and to make sure that we are considering our diverse attorneys for key opportunities and positions within our firm.
My most cherished parts about being the Chief Diversity Officer are the open and honest conversations that I have with my co-workers about ideas for new D&I efforts, their lived experiences, and their paths to becoming a lawyer. Through these open and vulnerable conversations, I learn so much from them and can incorporate their feedback into new efforts or changes to our existing efforts. We have to be able to adapt and tailor our efforts to the needs of our internal community, and having these conversations allows us to do just that.
I cannot wait to build upon my experience from the first full year to create even more impact for 2023!
Join Us for the 2023 Health Law Section Annual CLE Program
Health Law SectionPlease join your health law colleagues around the state for the NCBA Health Law Section’s annual CLE program, Friday, April 21, 2023. This year’s program – “Keeping a Finger on the Pulse” – will be offered in person at the North Carolina Bar Center in Cary and via live Webcast! You can receive up to 6.25 total CLE credits, including 1.0 hour of Ethics/Professional Responsibility credit. Generous sponsorships have enabled the section to offer this full day of CLE and networking opportunities to section members for only $225 (even less for students, law professors, judges and public interest lawyers).
This year’s program will include several hours of North Carolina specific healthcare content, including a Keynote presentation from Jay Ludlam, Assistant Secretary of the North Carolina Department of Health and Human Services, who will address the current health care landscape in North Carolina, including challenges navigating the post-pandemic environment and the North Carolina Medicaid program’s transformation from fee-for-service to a managed care delivery system.
The program will also provide networking opportunities including a continental breakfast, lunch and reception following the program. Make plans now and clear your schedule to attend this year’s exciting program on April 21. Registration is open now!
Requests for Tax-Exempt Organization Annual Returns
Tax SectionSection 6104(d)(1)(B) provides a right to taxpayers to request the application for tax exemption and annual informational returns for the last three years of any organization described in Section 501(c) or (d) and exempt from taxation under Sections 501(a) or 527(a). That covers both public charities and private foundations exempt under Section 501(c)(3), as well as other types of tax-exempt organizations.
Reg. § 301.6104(d)-1(d)(2) provides such tax-exempt entities must honor a written request for the documents required to be provided under Section 6104(d) provided the request (a) is addressed to, and delivered by mail, electronic mail, facsimile, or provide delivery service to a principal, regional, or district office of the organization, and (b) sets forth the address to which the copy of the documents should be sent. The charity, pursuant to Reg. § 301.6104(d)-1(d)(3), may require a reasonable fee for providing such copies. Pursuant to Reg. § 301.6104(d)-1(d)(2)(ii)(A), the charity must send the documents within 30 days of the date it receives the request or, if the charity requires payment in advance for the costs associated, 30 days from the date it receives such payment. If the individual making the request consents, the tax-exempt organization may provide the requested document exclusively by electronic mail.
Read more
2022 Pro Bono Reporting is Open for NC Paralegals
Paralegal DivisionIn 2022, the North Carolina Pro Bono Resource Center (the “PBRC”) launched a statewide voluntary Paralegal Pro Bono Reporting process for the first time. In 2022, 127 paralegals reported performing 1,983 hours of pro bono service throughout the year. Additionally, 13 of those paralegals who reported a combined 1,227 hours were inducted into the inaugural cohort of the North Carolina Paralegal Pro Bono Honor Society! The PBRC has once again opened pro bono reporting for paralegals to report their hours served in 2022. The reporting period closes on March 31, 2023. This process is open to all North Carolina paralegals, regardless of education or certification status.
While there is no requirement for paralegals to offer pro bono services in North Carolina, there is an ethical responsibility for attorneys to do so under North Carolina Rule of Professional Conduct 6.1, and Guideline 10 of the ABA Model Guidelines for Utilization of Paralegal Services states that “[a] lawyer who employs a paralegal should facilitate the paralegal’s participation in appropriate continuing education and pro bono publico activities.” Rule 6.1 encourages North Carolina attorneys to provide at least 50 hours of legal services per year at no cost to individuals of limited means and/or charitable or other organizations that serve individuals of limited means.
Read more
Zoning, Planning & Land Use Section: Student Scholarships
Zoning Planning & Land Use SectionIn 2022, the Zoning, Planning and Land Use Section awarded its first scholarships to deserving law students. In order to meet the requirements for the 2022 Scholarship, the recipient must have been an unpaid intern working in a North Carolina government or public interest law department (State, Federal, City or County) who was also enrolled in an American Bar Association accredited law school.
The ZPLU Section is accepting applications for its 2023 scholarship awards – now through April 15.
Last year’s recipients were Ashley Loveless, a 1L from the University of North Carolina School of Law, and Austin Morris, a 1L from Wake Forest University School of Law. By accepting this scholarship, Ashley and Austin agreed to write an essay about their experience as interns. Here is a synopsis of their essays.
Read more
Recent Cyberattacks on Health Care and the Consequences
Privacy and Data SecurityBy Judith Beach
According to a study from January 2016 to December 2021,[1] 374 ransomware attacks on U.S. health care delivery organizations exposed the Protected Health Information (PHI) of nearly 42 million patients. The cybercriminals demand ransom to unencrypt the exfiltrated medical data, and, as such, create a direct threat to public health and safety. In addition, if the facility refuses to pay, some hackers have started posting the sensitive health data on the dark web. Moreover, some of the breached facilities are being sued on behalf of the patients whose data was compromised. Consequently, these recent cyberattacks on health care have significantly increased the cost of cyber insurance. Here are a few examples of recent cyberattacks in health care.
Read more