Memo on HHS's NPRM: HIPPA Privacy Rule Accounting of Disclosures and Access Reports

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On May 31, 2011, the Department of Health and Human Services (“Department”) issued a Notice of Proposed Rulemaking (“NPRM”) as authorized by the HITECH Act of 2009. Primarily, the proposed changes revise 45 C.F.R. § 164.528 by dividing it into two separate rights available to individuals: (1) the right to an accounting of disclosures and (2) the right to an access report.

This memo proceeds in the following manner. Part II defines important key terms used in this memo. Parts III, IV and V follow the headings of the NPRM. Part III gives an outline of the distinction between an accounting of disclosures and an access report, and includes the Department’s intent and purpose for requiring access reports. Part IV provides a condensed, section-by-section explanation of the changes in the NPRM. Part V lists the effective and compliance dates for the proposed rule. Finally, Part VI gives a comprehensive list of the Department’s specific requests for comment.

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