HIPAA Final Rule: Today is Effective Date–Covered Entities and Business Associates Have 180 Days to Comply

March 26, 2013. Today is the first big milestone since publication in the Federal Register on January 25, 2013, of the Final Rule: Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act; Other Modifications of the HIPAA Rules. Today is the effective date of the Final Rule, and covered entities and business associates must comply by September 23, 2013.

HIPAA Final Rule: Enforcement by State Attorneys General

February 26, 2013. Today, we examine the HIPAA Rules enforcement role established by the HITECH Act for State attorneys general as modified in the Final Rule: Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act; Other Modifications of the HIPAA Rules, which was published in the Federal Register on January 25, 2013. The effective date of the Final Rule is March 26, 2013, and covered entities and business associates must comply by September 23, 2013. Tomorrow, we begin to examine modifications to the HIPAA Privacy Rule.

HIPAA Final Rule: Enforcement–Factors for Determining Civil Money Penalties for HIPAA Violations

February 25, 2013. Today, we examine factors considered in determining the amount of a civil money penalty for a HIPAA violation that are modified in the Final Rule: Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act; Other Modifications of the HIPAA Rules, which was published in the Federal Register on January 25, 2013. The effective date of the Final Rule is March 26, 2013, and covered entities and business associates must comply by September 23, 2013. Tomorrow, we examine the HITECH Act role of State Attorneys General in the enforcement process.

HIPAA Final Rule: Enforcement: Four Penalty Tiers

February 21, 2013. Today, we examine the four penalty tiers for violations of HIPAA Rules in the Final Rule: Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act; Other Modifications of the HIPAA Rules, which was published in the Federal Register on January 25, 2013. The effective date of the Final Rule is March 26, 2013, and covered entities and business associates must comply by September 23, 2013. Tomorrow, we look at the relationship of FERPA and HIPAA vis-a-vis disclosure of immunization records to schools, with a return to enforcement Monday and Tuesday of next week.

HIPAA Final Rule: Enforcement: Willful Neglect

February 20, 2013. Today, we begin examination of HITECH Act modifications of HIPAA Enforcement, focusing on the meaning and consequences of willful neglect in the Final Rule: Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act; Other Modifications of the HIPAA Rules, which was published in the Federal Register on January 25, 2013. The effective date of the Final Rule is March 26, 2013, and covered entities and business associates must comply by September 23, 2013. Tomorrow, we look at the penalty structure for violations of HIPAA Rules.

HIPAA Final Rule: Modification of Business Associate Definition, Part (6)–Exceptions

February 14, 2013. Today, we finish examining the business associate definition, focusing on exceptions, as modified by the Final Rule: Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act; Other Modifications of the HIPAA Rules, which was published in the Federal Register on January 25, 2013. The effective date of the Final Rule is March 26, 2013, and covered entities and business associates must comply by September 23, 2013. Tomorrow, we begin to examine new definitions in the Final Rule, and next week we look at modifications in the Final Rule regarding enforcement.

HIPAA Final Rule: Modification of Business Associate Definition, Part (5)–Subcontractors

February 13, 2013. Today, we finish examining (3)—the third paragraph of four—of the business associate definition, as modified by the Final Rule: Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act; Other Modifications of the HIPAA Rules, which was published in the Federal Register on January 25, 2013. The effective date of the Final Rule is March 26, 2013, and covered entities and business associates must comply by September 23, 2013. Tomorrow, we conclude the discussion of business associate by looking at four categories of persons in paragraph (4) that are excluded as business associates.

HIPAA Final Rule: Modification of Business Associate Definition, Part (4)–Personal Health Record Vendor

February 12, 2013. Today, we examine the role of the personal health record vendor in paragraph (3)—the third paragraph of four—of the business associate definition, as modified by the Final Rule: Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act; Other Modifications of the HIPAA Rules, which was published in the Federal Register on January 25, 2013. The effective date of the Final Rule is March 26, 2013, and covered entities and business associates must comply by September 23, 2013. Tomorrow, we take up the third of three parts of paragraph (3) of the modified definition of business associate: subcontractors.

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