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 Health Information Technology for Economic and Clinical Health Act ("HITECH") and finalizing other regulations that were previously issued in proposed form. The Omnibus Rule will officially be published Friday, January 25, 2013, with an "effective date" of March 26, 2013; however, HHS will not enforce most of the new provisions until September 23, 2013, thereby giving covered entities six months to implement fixes.

While the regulations are voluminous, the most important changes relate to a few specific areas: breach notifications; business associates and subcontractors; fundraising and marketing; "hybrid" entities; deceased patients; school immunization records; "notice of privacy practices" revisions; and the "hide" rule.