Written by Dianne J. Bourque and Stephanie D. Willis The HIPAA Omnibus Rule goes into effect today, which officially starts the clock for covered entities, business associates, and their subcontractors to begin updating their agreements, forms, policies, procedures, and practices to meet approaching compliance deadlines. Business Associate Agreement (BAA) and Data Use Agreement (DUA) compliance… Continue Reading
Tag Archives: Business Associate
The New HIPAA Omnibus Rule & Your Liability — A Detailed Review
Posted in Data Breach Notification, Data Compliance & Security, HIPAA/HITECH, Privacy RegulationBy Alden J. Bianchi, Dianne J. Bourque, Kimberly J. Gold, and Cynthia J. Larose As we have reported in this blog (here, here, here, here, and here), 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 Breach Notification Rules (Omnibus… Continue Reading
Proposed HITECH Regulations Out in May?
Posted in LegislationBuried in a part of today’s Federal Register was the publication of the Department of Health and Human Services’ regulatory agenda. The agenda presents a forecast of expected HHS rulemaking activities and suggests that in May of this year HHS will issue the long-awaited proposed rules to modify the HIPAA Privacy, Security, and Enforcement Rules… Continue Reading
HHS Announces Delay in Enforcement of HITECH Rules as Applied to Business Associates
Posted in LegislationAs we have discussed before, HHS’s Office of Civil Rights has let it be known that a proposed rule implementing the HITECH Act’s privacy and security provisions as they apply to business associate liability is in the works. The proposed rule will also deal with new limitations on the sale of protected health information, marketing,… Continue Reading