The Harlow Group LLC


Newton, MA, United States

Contact: David Harlow, Principal

New OIG Self-Disclosure Protocol

The OIG released an updated self-disclosure protocol this week, about ten months after putting out a call for comments on the old protocol. The new protocol imposes some new burdens on the disclosing entity, such as a shorter…more
| Administrative Law, Health

The Latest on Online Professionalism Standards for Physicans

The American College of Physicians (ACP) Ethics, Professionalism, and Human Rights Committee, the ACP Council of Associates, and the Federation of State Medical Boards (FSMB) Special Committee on Ethics and Professionalism spent…more
| Communications & Media Law, Health

PQRS: Alphabet Soup With Little Meaning

I'm quoted in the current issue of Medical Economics, on the subject of the Medicare PQRS: Physician Quality Reporting System. I'm not a big fan of PQRS, since it rewards reporting of process measures, not outcomes, and the…more
| Health

HIPAA Omnibus Final Rule - What's in it for Patients?

The Final Rule offers significant changes to patient rights and patient protections. (There is much more to the rule, but other aspects are not addressed in this post. Here you may find a link to the HIPAA Omnibus Rule, a…more
| Administrative Law, Health, Privacy, Science, Computers, & Technology

Final HIPAA Breach Notification Rule

While there is much to say about the broadening of the definition of business associate, the new obligations of business associates and their subcontractors, increased protections provided to patients (in terms of being able to…more
| Health, Privacy

HIPAA Omnibus Rule - Google+ Hangout

For a first look at the HIPAA omnibus rule, I had a Google+ Hangout on Air with Brian Ahier and Deven McGraw. We talked through the changes made to the privacy and security rules, the breach notification rule, the enforcement…more
| Administrative Law, Health, Privacy

Gimme My Damn Data - The ICD Edition

The latest news story to examine the issue of patient access to implantable cardiac defibrillator data (a variation on the theme of “gimme my damn data”) is an in-depth, Page One Wall Street Journal story featuring…more
| Administrative Law, Health, Privacy

OCR releases HIPAA privacy rule guidance on de-identifying PHI

Just two and a half years after hosting a workshop on the HIPAA Privacy Rule's de-identification standard, OCR has issued its "Guidance Regarding Methods for De-identification of Protected Health Information in Accordance with…more
| Administrative Law, Health, Privacy

CO-OPs - The Stealth Public Option Under the ACA?

Last week, the Massachusetts CO-OP was approved by the federales under a provision of the Affordable Care Act that was key to the Act's passage, yet not widely known. The Consumer Operated and Oriented Plan, known as the…more
| Health, Insurance

The Supreme Court and the ACA: 5-4? Really? What the decision is about. And not about.

The Roberts Court brought the curtain down on a fractious Term in a stranger-than-fiction kinda way. Roberts' opinion in the health reform case has been declared by many to be a high-minded approach to doing the right thing and…more
| Constitutional Law, Health

Nothing About Me Without Me

Meaningful Use Stage 2 regulations were released in March by CMS and ONC. Over the past month or so, I've been working with other members of the Society for Participatory Medicine (thank you, all) to prepare comments on these…more
| Administrative Law, Health

OCR HIPAA Audits Finally Kick Off - Do They Matter?

The HITECH Act called for stepped-up HIPAA privacy and security and breach notification rule enforcement with respect to covered entities and business associates, to be accomplished by spot-check audits. This month, the first…more
| Administrative Law, Health, Privacy

Accountable Care Organization Regulations - The ACO is a Camel, Not a Unicorn

The federal government is trying to reinvent the health care system through a variety of programs. One of them is the Accountable Care Organization program for Medicare. Another is a series of initiatives from the CMS Center for…more
| Administrative Law, Business Organizations, Health

Final Accountable Care Organization (ACO) Regulations - Blog Post & Webinar Announcement

Final Accountable Care Organization Regulations - Blog Post & Webinar Announcement Join David Harlow (aka HealthBlawg) for a free ACO webinar 10/27 at 1:00 p.m. ET. Shoot us some questions if you;d like to see them addressed in…more
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Health 2.0 - Fall 2011, San Francisco: Data Liquidity and High Quality, Low Cost Health Care

Health 2.0 - Focus on High Quality, Low Cost & Connectivity "The health care payor and provider worlds are concerned with access, cost and quality. The federal government adds a population health gloss, and calls it the Triple…more
| Health, Science, Computers, & Technology
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