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In light of the ongoing investigation of Change Healthcare’s ransomware attack that resulted in the improper disclosure of thousands of individuals’ PHI, now seems like a perfect time to discuss HIPAA’s requirements...more
Recently, lawsuits have been filed against Duke and WakeMed regarding their use of Meta’s Meta Pixel tracking product and the alleged improper disclosure of patients’ protected health information (“PHI”). The U.S. Department...more
Report on Patient Privacy 21, no. 3 (March 2021) - Sometime during the fall, a worker for a subcontractor of Humana Inc. decided to share actual member information from medical records via a Google document with people he...more
Many New Year’s Resolutions focus on actions intended to save money and reduce stress. Organizations, especially those in the health care industry, should consider a resolution to review their breach notification procedures...more
If you sponsor a group health plan that is subject to the HIPAA Privacy and Security Rules, it is time to review and revise your policies and procedures and re-train your employees regarding the proper procedures when...more
On March 22, 2013, Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) Director Leon Rodriguez presented the keynote address to attendees of the American Health Lawyers’ Association HIPAA/HITECH Conference in...more
On January 25, 2013, the U.S. Department of Health and Human Services (HHS) published the highly anticipated Omnibus Rule, which makes extensive changes (as promulgated by the Health Information Technology for Economic and...more
HHS has released its much-anticipated final omnibus rule about protected health information. The rule addresses privacy and security issues, including defining a business associate and expanding individuals' rights to...more
On January 25, 2013, the Office of Civil Rights (OCR) of the Department of Health & Human Services (HHS) published the long-awaited omnibus final regulation governing health data privacy, security and enforcement (Omnibus...more
In This Issue: - A Baker's Dozen of Significant Changes From the HIPAA/HITECH Rule 1. Business Associates and Subcontractors 2. Breach Notification 3. Covered Entity Organizational Structures 4. Cloud...more
HIPAA covered entities have through Friday, March 1, 2013, to report small breaches of unsecured protected health information that occurred in calendar year 2012 to the U.S. Department of Health and Human Services (HHS). A...more
On January 25, 2013, the Department of Health and Human Services (HHS) published final regulations that modify the Privacy, Security, Enforcement and Breach Notification Rules issued pursuant to the Health Insurance...more
On January 25, 2013, the Office for Civil Rights (OCR) of the U.S. Department of Health and Human Services (HHS) published a final rule (Final Rule) containing modifications to the privacy standards (Privacy Rule), security...more
As we have reported in this blog, the Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently released final regulations containing modifications to the HIPAA Privacy, Security, Enforcement, and...more
Originally posted in Hartford Business Journal on February 11th, 2013. Attention all medical providers, hospitals and any other covered entity or business associate under HIPAA. On Jan. 17, the U.S. Department of Health...more
The Office for Civil Rights of the Department of Health and Human Services (“OCR”) has issued final regulations modifying the Health Insurance Portability and Accountability Act (“HIPAA”) Privacy, Security, Breach...more
Changes to the HIPAA Enforcement Rule - Background: On October 30, 2009, HHS issued an interim final rule revising the Enforcement Rule to incorporate provisions of the HITECH Act. The NPRM then proposed a number of...more
Changes to the HIPAA Security Rule Background: The HIPAA Security Rule protects electronic PHI by requiring Covered Entities to implement certain administrative, physical, and technical safeguards surrounding...more
If your company is subject to HIPAA, new rules published by the Department of Health and Human Services (“HHS”) will require changes in your policies and practices regarding data breaches....more
In This Issue: - Brief Overview of Key Modifications in the Final Rule - Suggested Action Items for Compliance with the Final Rule ..Covered Entities ..Business Associates - Consequences of Noncompliance...more
The United States Department of Health and Human Services (the "Department") issued the "Omnibus" Final Rule (the "Final Rule") on January 17th, 2013. The Final Rule contains long-awaited rules and clarifications regarding...more
Beginning this fall, employer health plans—or their business associates—will have to make more comprehensive and methodical risk assessments following the discovery of an impermissible use or disclosure of unsecured...more
The HHS Office for Civil Rights (OCR) released the long-awaited HIPAA Omnibus Final Rule on January 17, 2013. - The HIPAA Privacy, Security, and Enforcement Rules to implement statutory requirements of the HITECH Act;...more
Nearly two years after the first anticipated publication date, the U.S. Department of Health and Human Services ("HHS") has finally published the "Omnibus" Final Rule implementing many changes to HIPAA called for by the...more