Report on Patient Privacy 22, no. 4 (April, 2022) - By many measures, David Northcutt’s unsuccessful 2018 bid for the Alabama senate was a costly one. Northcutt, a dentist, loaned his campaign $73,000 throughout the...more
On this blog, we have discussed the criticality of risk analyses – the assessment required by the Security Rule of the “risks and vulnerabilities” that an organization faces with respect to all of its electronic protected...more
The Department of Health and Human Services’ (“HHS”) Office for Civil Rights (“OCR”) is responsible for enforcing the Privacy and Security Rules of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”)....more
The US Department of Health and Human Services Office for Civil Rights recently posted guidance clarifying that a business associate such as an information technology vendor generally may not block or terminate access by a...more
On October 7, 2016, the U.S. Department of Health and Human Services’ Office for Civil Rights (OCR) published guidance to assist cloud service providers (CSPs) and their customers with HIPAA compliance. As discussed below,...more
Officials at the U.S. Department of Health and Human Services Office of Civil Rights (HHS OCR) have recently selected a vendor to conduct the second wave of HIPAA audits. These so-called “Phase 2 Audits” are set to commence...more
This week, the HHS Office of Civil Rights (OCR) issued a bulletin (Bulletin) to remind covered entities and business associates that “the protections of the Privacy Rule are not set aside during an emergency.” The...more
The September 23, 2013 deadline for covered entities, business associates and their subcontractors to implement the new HIPAA rules is approaching quickly. In case you missed it, on January 25, 2013, the U.S. Department of...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
In this information technology era, it is little wonder that the Obama Administration has made enforcement of data security and privacy protections a top priority. The enforcement emphasis reflects public opinion favoring...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
On January 25, 2013, the Department of Health and Human Services published the much-anticipated Omnibus Final Rule (the “Final Rule”), which, with respect to business associates and their subcontractors, conforms HIPAA’s...more
In This Issue: - Expansion of, Clarifications to, and Explicit Inclusions in the Definition of BA - BAs’ Direct Liability Under the Final Rule - BAAs: Required Provisions Under the Final Rule and the Compliance Date ...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
The Health Insurance Portability and Accountability Act/Health Information Technology for Economic and Clinical Health Act Omnibus Rule, published in the Federal Register Jan. 25, makes many changes to the HIPAA Privacy Rule,...more
On January 17, 2013, the Department of Health and Human Services (“HHS”) released its long awaited final HIPAA rule, which significantly expands certain obligations for healthcare providers and their business associates (the...more
The Office of Civil Rights (“OCR”) of the Department of Health and Human Services (“HHS”) published today the much anticipated final omnibus rule implementing the Health Information Technology for Economic and Clinical Health...more