Proposed Changes to HIPAA Accounting of Disclosures Provision and Proposed New Access Report Requirement

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On May 31, 2011, the U.S. Department of Health and Human Services published a proposed rule regarding the provisions of the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations concerning accounting of disclosures of electronic protected health information.

The proposed rule contains two main parts:

(1) modifications to the existing accounting of disclosures requirements and

(2) a new “access report” requirement.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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