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As more health care entities implement population health and care coordination initiatives, questions arise concerning the application of HIPAA to such efforts. Although HIPAA applies to protected health information used and shared by covered entities in connection with population health activities, in many circumstances HIPAA permits the use and sharing of such PHI without patient authorization or business associate agreements. READ MORE
The HHS Office for Civil Rights has issued a new fact sheet addressing direct liability of business associates for violations of HIPAA Rules. The fact sheet serves as a reminder that business associates have direct liability under HIPAA and are subject to enforcement for Rule violations. READ MORE
The Office of Civil Rights has asked for public input how the agency might modify the HIPAA Privacy, Security and Breach Notification Rules in a Request for Information. The 50 questions in the RFI reveals notable insights for the OCR’s future plans to improve care coordination and reduce regulatory burdens. READ MORE
Once mainly focused on large data breaches affecting 500 or more individuals, the OCR now intends to increase HIPAA enforcement actions on smaller breaches of unprotected protected health information. READ MORE
The OCR indicated that based on its enforcement experience, many individuals are having difficulties obtaining such access even as technology evolves, and new treatments make it important for individuals to have ready access to their PHI. READ MORE
Two recent HIPAA settlements remind organizations subject to HIPAA of the importance of having a robust HIPAA privacy and security compliance program in place. READ MORE
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