ONC Delays Enforcement of the Information Blocking Certification Provisions of its CURES Act Final Rule for 3 months

ONC Delays Enforcement of the Information Blocking Certification Provisions of its CURES Act Final Rule for 3 months

by | Apr 22, 2020 | , ,

Today, ONC announced that it will exercise its discretion in enforcing all new requirements under its Cures Act Final Rule which have compliance dates and time frames until 3 months after each such date identified in the Final Rule.  The ONC Final Rule is scheduled to be published on May 1, 2020 in the Federal Register.  The ONC has developed an “Enforcement Discretion Dates and Time frames” chart which indicates that the Part 170 Information Blocking provisions will have a compliance Enforcement Discretion Date of February 1, 2021.

read more
Summary List of COVID19-related Federal Actions Relevant to Healthcare

Summary List of COVID19-related Federal Actions Relevant to Healthcare

by | Apr 15, 2020 | ,

As efforts at the federal and individual states level evolve every day at almost a breakneck pace to address challenges and needs related to the COVID-19 outbreak, here is a running list of some of the top actions taken at the federal level that we thought would be helpful to the healthcare industry (Caveat, this is not an exhaustive list):  [updated: July, 28, 2021]

read more
Do I Need a HIPAA Business Associate Agreement?

Do I Need a HIPAA Business Associate Agreement?

by | Apr 5, 2020 | , ,

A HIPAA “Business Associate” is a person, other than a member of the workforce, who creates, receives, maintains or transmits PHI in the performance of services or functions for or on behalf of a Covered Entity. Treatment and Payment disclosures do NOT create a HIPAA BA relationship. Conduits are not HIPAA BAs, but the exception is very narrow. Covered Entities should review each HIPAA BA Agreement is needed, or not.

read more
“Top 10” List for Security Law Compliance

“Top 10” List for Security Law Compliance

by | May 28, 2015 |

“Top 10” List for Security Law Compliance As we bid farewell to late night comedy host David Letterman, I thought it appropriate and timely to give a nod to one of Letterman’s most iconic segments, his “Top 10”, with my own Top 10 list for complying with applicable Security Law: #10.  THE HIPAA...

read more

Note to Mr. Donald Trump: According to HHS’ New Omnibus Rule, You Can Have A Copy of That Birth Certificate in About 100 or so Years Because HIPAA Doesn’t Apply

by | Jan 27, 2013 |

Note to Mr. Donald Trump: According to HHS’ New Omnibus Rule, You Can Have A Copy of That Birth Certificate in About 100 or so Years Because HIPAA Doesn’t Apply One change under the Omnibus Rule that is somewhat flying under the radar is that HIPAA no longer will apply to a patients’...

read more

Archives