The Harlow Group LLC

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

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

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