Covered Entities

News & Analysis as of

Blog: Hospital and Vendor Reach Agreement to Settle Alleged HIPAA Violations with Connecticut AG

Last week, the Connecticut Attorney General (the “Connecticut AG”) announced that Hartford Hospital and its subcontractor, EMC Corporation (“EMC”), agreed to settle potential violations of the Health Insurance Portability and...more

The New York Department of Financial Services Releases Potential New Cybersecurity Rules

On November 9, Anthony Albanese, Acting Superintendent of the New York Department of Financial Services (the NYDFS), sent a letter to the 18 members of the Financial and Banking Information Infrastructure Committee (the...more

OIG Emphasizes Proactive Enforcement of Privacy Rule and Monitoring of Repeat Offenders

The Office of Inspector General’s (OIG) recently released Privacy Standards report assessed the Office for Civil Rights’ (OCR) oversight of covered entities’ compliance with the Privacy Rule as well as the extent to which...more

DWT Releases Latest Health Care Breach Charts

Safeguarding patient information is at the core of responsibilities for health care entities under the Health Insurance Portability and Accountability Act (HIPAA). But safeguarding patient information isn’t just a regulatory...more

NYC to Require Most Employers to Offer Qualified Transportation Benefits

Effective Jan. 1, 2016, the New York City Affordable Transit Act (the “Act”) will require covered employers to establish a program allowing full-time employees to designate up to the federal limit of $130 per month in pre-tax...more

Transportation Benefits Coming to D.C. Employees in 2016

In July 2014, the Council of the District of Columbia adopted and the then-mayor signed the Sustainable DC Omnibus Amendment Act of 2014, DC Law 20-385. The Act, among other things, brought about regulations and rules...more

States Take Aim At Health Insurance Providers Fee In New Litigation

Three states—Kansas, Louisiana and Texas—filed a complaint in federal court on October 22, 2015 challenging the constitutionality and legality of the Affordable Care Act’s health insurance providers fee. The health...more

D.C. Commuter Benefits Are Almost Here: Employers Must Comply by January 1

Employers with 20 or more employees working in the District of Columbia have fewer than 90 days to comply with a new law that requires them to offer commuter benefits to employees by January 1, 2016. Washington, D.C. is one...more

Reporting for Duty: HMDA Regs Finalized

Why it matters Reporting requirements for financial institutions under the Home Mortgage Disclosure Act (HMDA) regulations were finalized by the Consumer Financial Protection Bureau (CFPB), with most provisions of the...more

HIPAA and Text Messaging

Text messaging is pervasive. Doctors and other health care providers, covered entities, and business associates currently use (and embrace) the technology. Texting is easy, fast and efficient. It doesn’t require a laptop...more

Do New Anti-Trafficking Requirements Apply To Your Company?

As human trafficking and other forms of exploitation of labor continue to be a focus of public attention, requirements on some employers to prevent trafficking and related abuses have recently increased. ...more

OCR Audits to Begin in 2016

Beginning in 2016, the United States Department of Health and Human Services’ Office for Civil Rights (OCR) will conduct another round of audits to gauge compliance with privacy provisions in the Health Insurance Portability...more

Data-Harvesting Zombie Hackers, Blood-Thirsty Auditors, and Other Reasons to be Scared on Halloween

This Halloween, the scariest monsters might not be in your closet or under your bed. They may be overseas, orchestrating intrusions into your electronic medical record. Or they may be lurking in your own workforce, carrying...more

HHS’ Selection of Contractor Provides Latest Update on Impending Second Round of HIPAA Audits

On October 27, 2015, a U.S. Department of Health and Human Services (“HHS”) official stated that the agency has hired FCi Federal, a provider of management and professional services to government agencies in Ashburn, VA, to...more

HIPAA Double Take: What Health Plan Sponsors Need to Know Now

With the onslaught of Affordable Care Act changes, health plan sponsors have much to think about lately. Given the number of other issues affecting them, plan sponsors may feel that HIPAA privacy and security is an issue they...more

OIG Pushes OCR to Step Up HIPAA Enforcement

In two recent reports, each with a specific focus, the OIG strongly recommended that the Office for Civil Rights (OCR) step up its HIPAA oversight and enforcement activities. One report assessed the OCR’s oversight of covered...more

District Court in D.C. Vacates HHS’ Interpretive Rule Regarding Orphan Drug Exclusion from 340B Discount Pricing

In what amounts to a victory for the pharmaceutical industry, on October 14, 2015, the U.S. District Court for the District of Columbia vacated the interpretive rule issued by the U.S. Department of Health and Human Services...more

Summary of Final Rule Amending HMDA and What It Means for Covered Institutions

The Consumer Financial Protection Bureau (CFPB) has released a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act (HMDA), requiring most lenders to report certain information about mortgage...more

Alert: Proposed 340B Drug Pricing Program Omnibus Guidance - Defines "Eligible Patient"

On August 28, 2015, the Health Resources and Services Administration (“HRSA”) published the proposed 340B Drug Pricing Program Omnibus Guidance (“Omnibus Guidance”) which is intended to clarify for covered entities, such as...more

Does Invalidation of 340B Orphan Drug Rule Doom HRSA’s Guidance?

Our recent post on HRSA’s Omnibus Proposed Guidance for the 340B Drug Discount Program (Proposed Guidance) noted that since the DC District Court had yet to rule on the validity of HRSA’s “interpretive” 340B orphan drug rule,...more

Court Strikes Down 340B Orphan Drug Rule Again: Will This Impact the “Mega Guidance”?

A federal court vacated the Department of Health and Human Services’ (HHS) Orphan Drug Rule that had allowed certain 340B Drug Pricing Program (340B Program) hospital covered entities to receive discounted prices when...more

Orphan Drug Ruling Disrupts the 340B Program

On Wednesday, the United States District Court for the District of Columbia issued its highly anticipated opinion regarding the 340B orphan drug litigation. The Court ruled in favor of PhRMA, a trade association that...more

Alphabet Soup and Data Security

In the span of two days, mobile device users learned of two data breaches that could compromise their personal data. In one, Experian (a credit reporting agency) reported that it was hacked, potentially putting 15 million...more

HHS Releases Far-Reaching Proposed Rule to Prohibit Discrimination by “Covered Entities” Pursuant to Section 1557 of the...

On September 8, 2015, the U.S. Department of Health and Human Services (“HHS”) published a proposed rule titled “Nondiscrimination in Health Programs and Activities” (“Proposed Rule”)[1] to implement the nondiscrimination...more

Privacy, Security, Risk: What You Missed At IAPP Conference

Earlier this month, privacy and security professionals from around the globe gathered for “Privacy. Security. Risk. 2015”—the second joint conference between the International Association of Privacy Professionals and the...more

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