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E-mailing and Texting PHI: Beware HIPAA

The HIPAA Privacy and Security Rules require covered entities (including healthcare providers and health plans) and their business associates to protect patient information stored or transmitted electronically, including...more

Police-Ordered Blood Draws In Idaho

Law enforcement officers often request or demand that Idaho hospitals draw blood or conduct other tests on patients for law enforcement purposes; nevertheless, the general rule remains that patients (including persons in...more

Idaho's New Parental Consent Law: FAQs

Idaho’s new parental consent law took effect July 1, 2024. Under the new law: “[A]n individual shall not furnish a health care service or solicit to furnish a health care service to a minor child without obtaining the...more

Court Vacates HIPAA Online Tracking Guidance

On June 20, 2024, a Texas federal court vacated the Office for Civil Rights’ (OCR's) controversial guidance concerning Use of Online Tracking Technologies by HIPAA Covered Entities and Business Associates, available here....more

Avoiding HIPAA Penalties: A Checklist for Covered Entities

The HIPAA Privacy, Security, and Breach Notification Rules apply to healthcare providers who engage in certain electronic transactions, healthcare clearinghouses, and health plans, including employee group health plans with...more

Idaho's New Parental Access Law v. HIPAA

As discussed in our prior health law update, New Limits on Minor Consents in Idaho, effective July 1, 2024, parents generally will have the right to access the medical records of their unemancipated minor children subject to...more

To BAA or Not to BAA: Must You Have One?

HIPAA applies to both covered entities (e.g., healthcare providers and health plans) and their business associates. A “business associate” is generally a person or entity that “creates, receives, maintains or transmits”...more

Business Associate Agreements: Requirements and Suggestions

The HIPAA Privacy and Security Rules generally require covered entities (including most healthcare providers) to execute written agreements (“business associate agreements” or “BAAs”) with their business associates before...more

HIPAA and Subpoenas, Orders, and Administrative Demands

The HIPAA privacy rules (45 CFR § 164.501 et seq.) generally prohibit healthcare providers and their business associates from disclosing protected health information in response to subpoenas and other government demands...more

Employee Vaccine Information: Privacy Concerns

Given the COVID-19 vaccine mandates, employers—including healthcare entities—will need to confirm their employees’ vaccination status. Employers and healthcare providers must ensure they comply with privacy rules relating to...more

HIPAA, Business Associates, and the Conduit Exception

The HIPAA privacy and security rules impose significant requirements on covered entities and their business associates; violations may result in penalties ranging from $119 to $59,522 per violation. (45 CFR § 160.404; 45 CFR...more

HIPAA, Patient Access, and Designated Record Sets

With limited exceptions, HIPAA generally gives individuals the right to access or obtain copies of their protected health information ("PHI") from covered entities. (45 CFR § 164.524(a)). But the right of access does not...more

Modified HIPAA Rules for Sending Records to Third Parties

Thanks to a federal judge, the Office for Civil Rights has modified its rules for sending records to third parties. Covered entities are no longer required by HIPAA to send non-electronic protected health information (“PHI”)...more

Contacting Parents, Spouses or Others to Obtain Payment

Healthcare providers sometimes mistakenly assume that they cannot contact a patient’s spouse, parents, or other third parties to obtain payment without the patient’s consent. However, HIPAA generally allows healthcare...more

Business Associates’ Use of Information for Their Own Purposes

Business associates may want to use a covered entity’s protected health information (“PHI”) for the business associates’ own purposes, e.g., for their own product development, data aggregation, marketing, etc. However, with...more

IMGMA Q/A: Sharing PHI for Treatment Purposes

Question: May I share records with another healthcare provider without the patient’s authorization? Answer: It depends on the purpose. If the disclosure is for purposes of the patient’s treatment, including continuation of...more

Liability of Business Associates for HIPAA Penalties

The HITECH Act extended certain HIPAA obligations to business associates, including those entities that create, receive, maintain or transmit protected health information (“PHI”) on behalf of covered entities. Business...more

Identifying Business Associates: Make Sure You Have BAAs in Place

Failing to have HIPAA business associate agreements (“BAAs”) can result in significant penalties for healthcare providers and business associates. Last month, the OCR imposed a $500,000 settlement and robust corrective action...more

HIPAA Breach Notification: When and How to Self-Report

So you just discovered that protected health information (“PHI”) from your organization was improperly accessed or disclosed. Are you required to self-report the violation to the affected individual and HHS? HIPAA Breach...more

Handling HIPAA Breaches: Investigating, Mitigating and Reporting

HIPAA privacy and security violations can result in fines of $110 to $55,100 to covered entities (including healthcare providers and health plans) and their business associates. (45 CFR 160.404). If the violation resulted...more

Producing Records of Other Providers

There is a common misunderstanding that healthcare providers may not or should not produce medical records that were created by another healthcare provider. Under HIPAA, patients have a right to access all records that a...more

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