The Office for Civil Rights of the Department of Health and Human Services (HHS) recently issued a proposed regulation implementing certain provisions of Title I of the Genetic Information Nondiscrimination Act of 2008 (GINA) that clarifies the status of genetic information as protected health information under the HIPAA Privacy Rule. This proposal was issued at the same time as, but is separate from and should not be confused with, the interim final rule jointly issued by HHS, the Treasury Department (Treasury), and the Department of Labor (DOL) (the “joint interim final rule”) implementing the substantive provisions of Title I of GINA.