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Changing Landscape: Federal and State Regulators Focus on Protecting Consumer Health Data

Recent developments at the federal and state level demonstrate that regulators are focused on protecting consumer health data. Specifically, state and federal regulators want to close the gap between HIPAA-protected data and...more

HIPAA Breaches and Compliance: Key Findings & Lessons Learned from OCR’s Reports to Congress

The Office of Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) recently submitted two annual reports to Congress setting forth a summary of complaints and breaches reported to the OCR during...more

HIPAA: Top 5 Takeaways as HHS Addresses Misconceptions on Applicability to COVID-19 Vaccination Information

The federal Department of Health and Human Services (HHS) issued guidance on the applicability of HIPAA to COVID-19 vaccination information, directly addressing a number of misconceptions about when HIPAA does, or does not,...more

Appeals Court Vacates HIPAA Penalty Imposed Against M.D. Anderson

On January 14, 2021, the U.S. Court of Appeals for the Fifth Circuit vacated the civil monetary penalty (CMP) imposed by the Department of Health and Human Services (HHS) against the University of Texas M.D. Anderson Cancer...more

OCR Relaxes Enforcement on Providers Using Scheduling Apps for COVID-19 Vaccinations

On January 19, 2021, the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) issued a Notice of Enforcement Discretion (Notice) announcing that it will not impose penalties for...more

Proposed Modifications to HIPAA Expands Individual Access Rights and Encourages Further Sharing of PHI for Care Coordination

On December 10, 2020, the Department of Health and Human Services, Office for Civil Rights (OCR) issued a Notice of Proposed Rulemaking (NPRM) to revise the HIPAA Privacy Rule. The proposed revisions to the Privacy Rule seek...more

HIPAA Right of Access Initiative: 2020 Year in Review

In 2020, the Office for Civil Rights (OCR) kept the promise it made the prior year to “vigorously enforce” the rights of patients to access and exercise control over their medical records. OCR has settled ten “right of...more

Managing the Commercial Impact of the Coronavirus: Implications for Health Care

The coronavirus (provisionally named SARS-CoV-2, with its disease being named COVID-19) has now been documented in more than 100 countries and territories. Over 120,000 cases have now been documented across the globe,...more

HIPAA: OCR Releases New FAQs Clarifying Disclosures Amongst Covered Entities

On June 26, 2019, the Department of Health and Human Services Office for Civil Rights (OCR) issued two new FAQs that clarify: The parameters around covered entities sharing protected health information (PHI) for a...more

OCR Clarifies Direct Liability for Business Associates under HIPAA

On May 24, 2019, the Department of Health and Human Services Office for Civil Rights (OCR) issued a new fact sheet which lists the provisions of the HIPAA Privacy, Security, Breach Notification, and Enforcement Rules (HIPAA)...more

Happy New Year! Potential Changes to HIPAA Requirements on the Horizon

On December 12, 2018, the U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR), requested public comments on potential changes to the Health Insurance Portability and Accountability Act’s...more

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