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Compliance considerations following Texas Court decision vacating key provisions of 2024 HIPAA Privacy Rule protecting...

The U.S. District Court for the Northern District of Texas vacated key portions of the 2024 updates to the HIPAA Privacy Rule that had strengthened protections for reproductive health care information. HIPAA-regulated...more

New York’s Health Information Privacy Act: what you need to know

If enacted, the New York Health Information Privacy Act (“NYHIPA”) will be the latest in a series of state privacy laws that regulate health data outside of the traditional health care context. It would follow the passage of...more

Federal court strikes blow to expansive OCR web tracking position

The ability of OCR to enforce expansive portions of its controversial web tracking guidance has been severely limited. A federal district court ruled that the guidance exceeded the agency’s authority, and in particular...more

FTC finalizes revised health breach notification rule expanding its scope and updating companies’ obligations

On May 30, 2024, the FTC published amendments to its Health Breach Notification Rule (“HBNR” or “Rule”) in the Federal Register, memorializing the Rule’s expanded scope that now explicitly includes direct-to-consumer health...more

HHS final rule requires HIPAA compliance changes for reproductive health care information

The HIPAA Privacy Rule has been modified by the US Department of Health and Human Services (HHS) to increase privacy protections for reproductive health care information. These changes, which will take effect in early 2026,...more

Updated OCR guidance does not solve HIPAA’s tracker uncertainty

The Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS) updated its guidance concerning compliance obligations for HIPAA covered entities and business associates using online tracking...more

HHS finalizes Part 2 substance use disorder rules enhancing privacy protections and care integration

The U.S. Department of Health and Human Services (HHS) has finalized amendments to more closely align the Part 2 substance use disorder (SUD) regulations with HIPAA. These changes have the potential to streamline compliance...more

FDA permits IRB informed consent waivers for minimal risk clinical trials

The U.S. Food and Drug Administration (FDA) has published a final rule on “Institutional Review Board Waiver or Alteration of Informed Consent for Minimal Risk Clinical Investigations,” which permits an exception from the...more

U.S. Senator requests information on ways to improve privacy protections of health data

Adding to the growing trend of policymakers interested in regulating health and wellness data, last week U.S. Senator Bill Cassidy requested stakeholder feedback to help identify solutions to modernize HIPAA and ensure all...more

Proposed HIPAA changes seek to protect reproductive health care

The U.S. Department of Health and Human Services (“HHS”) is proposing changes to HIPAA that would increase protections for reproductive health care information. If finalized, these changes would prohibit HIPAA-regulated...more

HHS OCR creates new HIPAA enforcement arm and enhances focus on cybersecurity and privacy oversight

This week the U.S. Department of Health and Human Services, the agency responsible for HIPAA enforcement, announced the formation of three new divisions within the Office for Civil Rights (“OCR”). The new divisions –...more

The online health data ecosystem takes another regulatory hit

Health companies cannot use online tracking technologies like other consumer organizations. This refrain, repeated frequently by regulators, litigants and the media in recent months, may now have found its clearest voice in...more

On notice: Proposed changes to SUD rules may alter HIPAA notice of privacy practices requirements

HIPAA covered entities will be required to change their HIPAA Notices of Privacy Practices (NPPs) if a recent proposed rule by the US Department of Health and Human Services is finalized. The Proposed Rule is designed to...more

HHS proposes significant changes to Part 2 substance use disorder records regulations

The U.S. Department of Health and Human Services (HHS) has proposed to significantly revise rules governing patient records in substance use disorder (SUD) programs, commonly known as the Part 2 rules, with important...more

HHS highlights significance of new healthcare technologies in series of regulatory actions

Recent U.S. Department of Health Human Services (HHS) regulatory actions emphasize the role emerging technologies play in the provision of healthcare, particularly as clinical innovations proliferate in response to the...more

Panelists sum up state of health care AI regulation, standards, and data challenges

At our recent Health Care AI Law and Policy Summit, Hogan Lovells partner Melissa Bianchi moderated a panel discussion on the state of the health care AI industry. Joined by representatives from the American Medical...more

FTC emphasizes expectations around the health breach notification rule

The Federal Trade Commission (FTC) recently has signaled its intent to inject new life into a longstanding but rarely triggered rule governing health breach notifications for non-HIPAA-covered health records. Specifically,...more

NIH requests feedback on its genomic data sharing policy

The National Institutes of Health has issued a request for information (RFI) on its Genomic Data Sharing (GDS) Policy to help ensure it keeps pace with the evolving genomic research landscape. The RFI will help inform...more

California and Florida contribute to web of state genetic privacy protections

States continue to enact laws targeting the protection of genetic data with two important developments in California and Florida. California’s Genetic Information Privacy Act (“GIPA”), which came into effect on January 1,...more

HHS proposes changes to key provisions of the HIPAA Privacy Rule

HIPAA Privacy Rule changes that have the potential to significantly impact patients, covered entities, and business associates were proposed by the Department of Health and Human Services (HHS) in a Notice of Proposed...more

California Consumer Privacy Act: The Challenge Ahead – Four Key Considerations For Health And Life Sciences Companies

This is the sixth installment in Hogan Lovells’ series on the California Consumer Privacy Act. The California Consumer Privacy Act of 2018 (CCPA) adds another set of privacy requirements for health and life sciences...more

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