Field Notes · 5 published / Working memos on security, compliance & AI governance Written by a named author · Retracted in print when wrong
Nexurion · EditorialFive volumes · May 2026

Nexurion Field Notes.

Working memos from a senior practitioner. Each one is written on the engagement that prompted it, signed by name, and retracted in print when we get it wrong. Written for the people who sign the audit response, not the ones who patch the finding.

Cadence
As ready
Not on a marketing schedule
Latest, Vol. V
4 May 2026
HIPAA training as evidence
Author of record
Jack Giordano
Founder · Marine · Firefighter
Volumes published
Five
More in draft
§ I · The latest volume
Vol. V · HIPAA · Workforce · 7 pages

Your annual training certificate is a receipt. OCR wants a sanctions program.

Most HIPAA workforce-training programs end the day the certificate prints. OCR’s 2024 and 2025 enforcement actions name the ones that didn’t. No sanctions trail, no role-based reinforcement, no evidence the training changed behavior. A field reading on what business-associate-led organizations should package instead.

A training certificate is evidence that the workforce received training. It is not evidence that the workforce operates under training. OCR, in 2025, started writing settlements that turn on the second sentence. Vol. V · The Misread
In this volume7 pp · ~11 min
  1. What OCR actually asks for in a training file.01
  2. The four documents that turn a certificate into a sanctions program.02
  3. Three settlements from 2024 and 2025 where training was the finding.04
  4. A 90-day rebuild for BA-led HIPAA programs.06
§ II · The five volumes
Five published · more in draft · no marketing schedule

Five volumes, in order of arrival.

We publish a Field Note when a position is ready, not when a calendar says it is. Each volume is tied to an engagement we ran or a regulation we read in the wild. If a memo misses its window, it stays in drafts until the window comes back around.
In drafting: SOC 2 + ISO 27001 in one period · The SoA as strategy document · The 60-day breach clock, by the hour.
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Author
Signed
Every volume, by name
Corrections
In print
Retracted when wrong, with a date
Editing
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Nothing edited for marketing
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