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Affordable Care Act Preventative Care Mandate At Risk Pending Supreme Court Decision

A case pending before the Supreme Court could jeopardize the Affordable Care Act’s (ACA) mandate that certain preventive services be provided on a first dollar coverage basis to plan members. Kennedy v. Braidwood Management...more

FDA Announces Completion of AI-Assisted Scientific Review Pilot and Deployment of Agency-Wide AI-Assisted Review

On May 8, 2025, the Food and Drug Administration (FDA) announced the completion of its generative artificial intelligence (AI) pilot program for scientific reviewers. FDA Commissioner Marty Makary was quoted in the...more

FDA Releases Draft Guidance on Submission Recommendations for AI-Enabled Device Software Functions

On January 7, 2025, FDA published a draft guidance titled “Artificial Intelligence-Enabled Device Software Functions: Lifecycle Management and Marketing Submission Recommendations.” The draft guidance was long-anticipated; it...more

HHS Office for Civil Rights Issues Guidance Regarding HIPAA Requirements for Online Tracking Technologies

On December 1, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services provided guidance on the intersection of the Health Insurance Portability and Accountability Act (HIPAA) and the use of...more

FTC Signals Increased Enforcement Effort Against Ineffective Data Security Protocols

With two recent enforcement actions, the Federal Trade Commission (FTC) has shown that administering appropriate data security policies is an area of priority. On October 24, 2022, the FTC announced a Proposed Consent Order...more

FTC Warns Health Apps and Connected Device Companies to Comply with the Health Breach Notification Rule

On September 15, 2021, the Federal Trade Commission (“FTC”) issued a Policy Statement instructing health app and connected device companies to comply with the Health Breach Notification Rule (“the Rule”). The Rule, codified...more

Supreme Court Accepts Narrow Definition of Autodialer, Limiting Reach of TCPA

On April 1, in a highly anticipated decision that likely will have a significant effect on litigation under the Telephone Consumer Protection Act (TCPA), the Supreme Court ruled on what qualifies as an “automatic telephone...more

HIPAA Enforcement Discretion During the COVID-19 Public Health Emergency

Over the last two months, the U.S. Department of Health and Human Services (“HHS”) published guidance regarding the enforcement of HIPAA and its privacy and security requirements in response to the COVID-19 public health...more

CMS and ONC Release Interoperability and Patient Access Final Rules

On March 9, 2020, CMS released its final rule creating certain interoperability and patient access standards (CMS Final Rule). On the same day, the ONC released a rule that addressed interoperability as well (ONC Final...more

DoD Releases Version 1.0 of the Cybersecurity Maturity Model Certification Framework

On January 31, 2020, the Department of Defense (DoD) released the latest version (Version 1.0) of its Cybersecurity Maturity Model Certification (CMMC) framework, setting forth future cybersecurity requirements for thousands...more

FDA FY 2021 Budget Foretells Medical Device Cybersecurity Reform

Increased premarket submission and post-market reporting requirements potentially on the horizon for high-tech devices. The Food and Drug Administration’s (“FDA’s”) budget proposal for FY2021 telegraphs FDA’s plan to seek new...more

Why Complete an Enterprise Risk Assessment

Your Organization’s best defense in an environment of aggressive regulators and litigious plaintiffs’ counsel is the completion of an enterprise risk assessment. Regulators and attorneys general are fining–sometimes hundreds...more

HHS Leverages NIST Cybersecurity Framework in Voluntary Health Sector Guidelines

In its most recent cybersecurity initiative, the U.S. Department of Health and Human Services (HHS) has released Health Industry Cybersecurity Practices: Managing Threats and Protecting Patients, described as a set of...more

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