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HHS OCR Proposes Significant Modifications to HIPAA Security Rule

§ 160.101 Statutory basis and purpose. The requirements of this subchapter implement sections 1171–1180 of the Social Security Act (the Act), sections 262 and 264 of Public Law 104–191, section 105 of Public Law 110–233,...more

OCR Withdraws Appeal in AHA v. Becerra

On August 29, 2024, the US Department of Health and Human Services (HHS) Office for Civil Rights (OCR) withdrew its appeal of the US District Court for the Northern District of Texas’s June 20, 2024, decision in American...more

OCR Files Notice of Appeal in Online Tracking Technologies Case

On August 19, 2024, the US Department of Health and Human Services Office for Civil Rights (OCR) filed a notice of appeal of the US District Court for the Northern District of Texas’s June 20, 2024, decision in American...more

Federal Court Invalidates Key Part of HHS OCR Bulletin Regarding Application of HIPAA to Online Tracking Technologies

In a consequential decision for Health Insurance Portability and Accountability Act (HIPAA)-regulated entities, on June 20, 2024, the US District Court for the Northern District of Texas ruled in American Hospital Association...more

FTC Amends Health Breach Notification Rule to Regulate Health Apps and Expand Breach Notification Requirements

On April 26, 2024, the Federal Trade Commission (FTC) issued a final rule to amend its Health Breach Notification Rule (HBN Rule). The HBN Rule works as a complement and counterpart to the breach notification requirements...more

HHS’s CARES Act Final Rule Better Aligns Part 2 Substance Use Disorder Patient Records Confidentiality Regulations with HIPAA

On February 8, 2024, the US Department of Health and Human Services (HHS) Office for Civil Rights (OCR) and Substance Abuse and Mental Health Services Administration (SAMHSA) jointly issued a final rule to amend the...more

OCR Update on Tracking Technologies Provides Little Relief for HIPAA-Regulated Entities

On March 18, 2024, the US Department of Health and Human Services Office for Civil Rights (OCR) issued an update to its December 1, 2022, bulletin titled “Use of Online Tracking Technologies by HIPAA Covered Entities and...more

Change Healthcare Security Incident – Practicable Next Steps for Impacted Customers

The Change Healthcare ransomware attack presents potentially significant ramifications for hospitals, health systems, pharmacies and others that rely on the organization’s tools for healthcare payment, revenue cycle...more

FTC Proposes Health Breach Notification Rule Amendments

The Federal Trade Commission (FTC), at its May 18, 2023, open Commission meeting, voted unanimously to issue a Notice of Proposed Rulemaking to amend the Health Breach Notification Rule (HBNR). The FTC’s proposed amendment...more

Major Changes Proposed to Substance Use Disorder Confidentiality Law

In a Notice of Proposed Rulemaking published December 2, 2022 (the Proposed Rule), the United States Department of Health and Human Services (HHS) proposed long-awaited changes to the regulations protecting the...more

HHS Issues Guidance on Requirements Under HIPAA for Online Tracking Technologies, Addressing Privacy and Security Concerns Related...

On December 1, 2022, the Office for Civil Rights (OCR) at the US Department of Health and Human Services (HHS) issued a Bulletin on the obligations of covered entities and business associates (regulated entities) under the...more

FTC Issues Policy Statement Expanding Interpretation of Health Breach Notification Rule’s Scope

On September 15, 2021, the Federal Trade Commission (FTC) voted 3–2 along party lines (with Republican commissioners dissenting) to issue a policy statement announcing an expansive interpretation of the FTC’s Health Breach...more

OCR Issues Proposed Modifications to HIPAA Privacy Rule to Remove Barriers to Coordination of Care and Reduce Regulatory Burden

On December 10, 2020, the US Department of Health and Human Services (HHS) Office for Civil Rights (OCR) issued a Notice of Proposed Rulemaking (NPRM) with proposed modifications to the Standards for the Privacy of...more

OCR Waives Penalties for Certain PHI Use, Disclosure by Business Associates During COVID-19 Emergency

On April 2, 2020, the US Department of Health and Human Services, Office for Civil Rights announced that it will not impose civil money penalties against covered entity health care providers or their business associates for a...more

Significant Increase in Ransomware Attacks on Healthcare Industry – OCR Offers Guidance

Recent months have seen a wave of ransomware attacks in the US healthcare industry, many involving a sophisticated strain of malware called Ryuk. To protect themselves, healthcare providers should review OCR’s recent guidance...more

Collaborative Transformation - Focus on Innovation Centers - Avoiding Pitfalls in Data-Focused Collaborations, Ventures and...

There are myriad opportunities for hospitals and health systems (HHSs) to engage in data-focused collaborations with other stakeholders in the healthcare industry. These collaborations include, to an increasing extent,...more

Healthcare Enforcement Quarterly Roundup | Q2 2019

In this second installment of the Healthcare Enforcement Quarterly Roundup for 2019, we cover several topics that have persisted over the past few years and identify new issues that will shape the scope of enforcement efforts...more

OCR Requests Information from Stakeholders on Significant Changes to the HIPAA Rules

The US Department of Health and Human Services, Office for Civil Rights (OCR) published a long-awaited Request for Information seeking feedback on whether and how the HIPAA Rules should be revised to better promote...more

On the Subject - The Continuing Disconnect between the Health Care Industry and OCR on HIPAA’s Risk Analysis Requirement

Lack of a sufficient risk analysis continues to be one of the most commonly alleged violations in Office for Civil Rights (OCR) HIPAA enforcement actions, appearing in half of all OCR settlements announced in the last 12...more

OCR Explains How Information Blocking Violates HIPAA

The US Department of Health and Human Services Office for Civil Rights recently posted guidance clarifying that a business associate such as an information technology vendor generally may not block or terminate access by a...more

HHS Office of Inspector General Calls for Increased Oversight and Enforcement of HIPAA

On September 29, 2015, the U.S. Department of Health & Human Services Office of the Inspector General (OIG), Office of Evaluation and Inspections, released two studies calling on the HHS Office for Civil Rights (OCR) to...more

OCR Launches Phase 2 HIPAA Audit Program with Pre-Audit Screening Surveys

Health Insurance Portability and Accountability Act of 1996 (HIPAA) covered entities have reported that the U.S. Department of Health and Human Services Office for Civil Rights (OCR) recently sent pre-audit screening surveys...more

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