Elite was also found not to have included the minimum required content in its Notice of Privacy Practices as required by the HIPAA Privacy Rule (45 C.F.R. § 164.520(b)). OCR agreed to pay a HIPAA violation fine of $10,000 and implement a corrective action plan (CAP) to resolve the alleged HIPAA violations and settle the case with no admission of liability. The three possible HIPAA violations could have resulted in a substantially higher financial penalty; however, when considering an appropriate financial penalty, OCR took the financial position of the practice, its size, and Elite's working with the OCR investigation into account. OCR Director, Roger Severino said: "Social media is not the place for providers to discuss a patient's care. Doctors and dentists must think carefully about patient privacy before responding to online reviews."