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OCR Webinar On HIPAA And COVID-19: Key Points For Covered Entities And Business Associates

Fox Rothschild LLP partner Beth Larkin listened to the HHS Office for Civil Rights 4/24/20 webinar (which should be posted on its website at some point) regarding HIPAA and COVID-19 and took notes. Here’s my summary of key...more

Three Ways Businesses Can Use The SHIELD Act To Protect Against Rising COVID-19 Cyber Fraud

While the COVID-19 pandemic has slowed the world economy to a crawl, the pace of cyberattacks has only increased as cybercriminals exploit the outbreak to steal money and valuable private information from businesses. Law...more

COVID-19 Update: Limited Waiver Of HIPAA Sanctions And Penalties For Certain Hospitals

Effective March 15, 2020, certain hospitals that fail to comply with specific HIPAA Privacy Rule requirements will not be subject to HIPAA sanctions and penalties, according to a “COVID-19 & HIPAA Bulletin” issued by U.S....more

FAQs On HIPAA Privacy And COVID-19

Fox Rothschild partner Bill Maruca’s article, “Protecting Privacy During an Infectious Disease Panic”, is (unfortunately) as relevant today as it was when it was posted more than 5 years ago. Swap Ebola for COVID-19, and the...more

Does the HIPAA Concept Of De-identification Serve To Adequately Protect The Privacy Of All Personal Health Information?

Some twenty-three years ago, the first well-publicized incident of the re-identification of de-identified personal health data was brought to the attention of the American public. It involved the then governor of...more

Tell Me Again: What Can Covered Entities (Or Their Business Associates) Charge For Medical Records Requests?

The answer to this question has changed yet again. I’ve blogged on this topic several times in the past, and described the question as a wriggling worm. Plaintiff Ciox Health, LLC has finally managed to catch that worm and...more

HIPAA versus FERPA: New Joint Guidance Highlights Emergencies And Complexities

More than eleven years have passed since the U.S. Department of Health and Human Services (HHS), the agency responsible for the privacy of protected health information under HIPAA, and the U.S. Department of Education (DOE),...more

The California AG May Be Watching You, Covered Entity

As Fox partner Odia Kagan posted yesterday, early enforcement of CCPA will focus on data related to kids. In addition, according to a recent article in the San Francisco Chronicle, the California Attorney General will focus...more

Clear Message From OCR: Don’t Ignore (Or Overcharge For) Patient Requests For Records

Last week, the Office for Civil Rights (OCR) announced its second enforcement action and settlement with a provider for failing to comply with HIPAA’s patient access requirements. Korunda Medical, LLC, a primary care and...more

How The Grinch Steals Health Care Data: OCR Warnings And Tips In Time For The Holidays

More and more often, health care data is stolen or made inaccessible by targeted ransomware attacks. The Office for Civil Rights (OCR) published a newsletter this week that provides warnings for HIPAA covered entities and...more

One Of Three $3 Million Lessons: Encrypt Mobile Devices

A large New York hospital system learned this lesson the expensive way. According to a U.S. Department of Health and Human Services (HHS) press release issued earlier this week, the Office for Civil Rights (OCR) investigated...more

U.S. States And Territories Data Breach Statutes

Fox Rothschild’s Privacy and Data Security practice group maintains this searchable PDF document as well as the Data Breach 411 app to inform businesses of the breach notification statutes in each of the 50 states, Guam,...more

Back To School And Back To BAAs: OCR Guidance Provides Reason To Review BAA Provisions

Last May, around the time many schools let out for the summer, the Office for Civil Rights (“OCR”) published guidance entitled “Direct Liability of Business Associates” (the “Guidance”), which focuses, not surprisingly, on...more

Where HIPAA Stops, CCPA Begins

Why Covered Entities and Business Associates Cannot Ignore the New California Data Privacy Law- The California Consumer Privacy Act (CCPA) applies to a wide range of for-profit businesses that collect the personal...more

Too Much (Protected Health) Information Exposed + Too Little Response = $3M And Corrective Action Plan For Medical Imaging Company

“TMI” usually means “too much information”, but it was used aptly by the Office for Civil Rights (OCR) as an acronym for a covered entity that exposed protected health information (PHI) of more than 300,000 patients through...more

Feeling Lucky? You Could Be One Of The Nine Covered Entities Selected For HIPAA Compliance Review This Month

If you are a covered entity health plan or clearinghouse, you may be among the nine (un)lucky entities randomly chosen this month for review into compliance with HIPAA’s Administrative Simplification rules governing...more

HIPAA Security And “Zero Day” Exploits: How To Stay Ahead Of The Hack

HHS Office for Civil Rights (OCR)’s April 3, 2019 cybersecurity newsletter highlights one of the more challenging cybersecurity vulnerabilities faced by covered entities and business associates. OCR reminds covered entities...more

Don’t Miss Your Opportunity To Tell HHS How To Improve HIPAA

The U.S. Department of Human Services’ Office for Civil Rights has set a Feb. 12 deadline for stakeholders to comment on how it should modify HIPAA, especially the Privacy Rule, to promote coordinated, value-based health...more

Entities That Comingle EU And U.S. Citizens’ Data Should Review Data Breach Notification Practices

If you are a U.S.-based entity that is subject to the EU Data Protection Regulation (GDPR), and you store personal data of EU residents and personally identifiable information of U.S. residents in a commingled database, you...more

To BAA Or Not To BAA? The Question A Florida Provider Should Have Asked In 2011 Results In A Half Million Dollar Payment In 2018

Yesterday’s listserv announcement from the Office for Civil Rights (OCR) within the U.S. Department of Health and Human Services (HHS) brought to mind this question. The post announces the agreement by a Florida company,...more

New Apple Watch May Mark Time To Rethink HIPAA

The new Apple Watch Series 4® is one of the more recent and sophisticated consumer health engagement tools. It includes a sensor that lets wearers take an electrocardiogram (ECG) reading and detect irregular heart rhythms....more

The California Consumer Privacy Act

Companies that are getting acclimated to the European Union’s General Data Protection Regulation (GDPR) have a new and just as significant compliance challenge to confront: The California Consumer Privacy Act. Signed into...more

The Heavy Hit Of HIPAA: Violations May Send You To Jail

The recent criminal conviction of a Massachusetts physician provides a stark reminder that violating HIPAA can result in more than civil monetary penalties and the financial and reputational fall-out that results from a...more

When HIPAA Compliance Is Not Enough: The Territorial Scope Of GDPR

The European Union’s General Data Protection Regulation (GDPR) went into effect on May 25, 2018. Whereas HIPAA applies to particular types or classes of data creators, recipients, maintainers or transmitters (U.S. covered...more

The Cost For A Copy Of Medical Records? It May Depend Who’s Asking

The Report to Congressional Committees of the U.S. Government Accountability Office (“GAO Report”), required under the 21st Century Cures Act, came out about a month earlier than required, but this early bird failed to catch...more

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