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FTC Amends Health Breach Notification Rule to Regulate Health Apps and Expand Breach Notification Requirements

On April 26, 2024, the Federal Trade Commission (FTC) issued a final rule to amend its Health Breach Notification Rule (HBN Rule). The HBN Rule works as a complement and counterpart to the breach notification requirements...more

Ten Takeaways From Long-Awaited Section 1557 Nondiscrimination Protections

On April 26, 2024, the US Department of Health and Human Services (HHS) issued a final rule (press release, fact sheet, FAQs) reinterpreting Section 1557 of the Affordable Care Act (ACA), which prohibits discrimination on the...more

Special Report: Understanding ONC’s Health AI Transparency and Risk Management Regulatory Framework

The Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing (HTI-1) final rule, issued by the US Department of Health and Human Services (HHS) Office of...more

HHS’s CARES Act Final Rule Better Aligns Part 2 Substance Use Disorder Patient Records Confidentiality Regulations with HIPAA

On February 8, 2024, the US Department of Health and Human Services (HHS) Office for Civil Rights (OCR) and Substance Abuse and Mental Health Services Administration (SAMHSA) jointly issued a final rule to amend the...more

NYDFS Issues Proposed Guidance on AI and External Consumer Data Use

On January 17, 2024, the New York State Department of Financial Services (NYDFS) issued a proposed Circular Letter that provides guidance for authorized insurers using external consumer data and information sources (ECDIS)...more

ONC’s HTI-1 Final Rule Adopts New Health IT Certification Requirements

On December 13, 2023, the US Department of Health and Human Services (HHS) Office of the National Coordinator for Health Information Technology (ONC) issued the Health Data, Technology, and Interoperability: Certification...more

New ONC Final Rule Expands Information Blocking Regulatory Exceptions

On December 13, 2023, the US Department of Health and Human Services (HHS) Office of the National Coordinator for Health Information Technology (ONC) issued the Health Data, Technology, and Interoperability: Certification...more

New Year, New Laws: California Healthcare Providers Subject to New Requirements in 2024

The California legislature has created a lot of holiday homework for California healthcare providers, passing more than 50 new laws regulating a wide range of healthcare providers and healthcare business operations that apply...more

New Cyber, Privacy and Automated Decisionmaking Rules Coming Soon to California

Substantial changes to the California Consumer Privacy Act (CCPA) are coming soon through five sets of proposed regulations governing (1) cybersecurity audits, (2) privacy risk assessments, (3) artificial...more

California’s New Reproductive Privacy Laws AB 352 and AB 254 Create Complexities For Health Information Sharing

In the wake of the Supreme Court of the United States’s decision in Dobbs v. Jackson Women’s Health Organization and the adoption of laws outside California that criminalize most abortions as well as gender affirming care,...more

HHS Issues Provider Information Blocking Disincentives Proposed Rule

On October 30, 2023, the US Department of Health and Human Services (HHS) Office of the National Coordinator for Health Information Technology (ONC) and the Centers for Medicare & Medicaid Services (CMS) released a...more

Landmark Executive Order on AI: What Does It Mean for Healthcare?

On October 30, 2023, the White House released a long-awaited Executive Order (EO) on the “Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence.” The EO acknowledges the transformative potential of AI...more

Recent Developments Related to Generative AI and Copyright Law

The increasing sophistication of generative artificial intelligence (AI) has had widespread effects on fields ranging from art and film to law and healthcare. The implications for copyright law principles, such as authorship,...more

For the General Counsel’s Desk: Managing Enforcement Risks Involving Cookies, Pixels, and Other Tracking Technologies

Data governance is a mission-critical issue for every company and institution in the United States. GCs face a host of pressing cybersecurity concerns. Triaging them requires time, attention, and a well-rounded strategy...more

Special Report - Decoding Genomic Data Security: Lessons from FTC’s Vitagene Enforcement and the NIST CSF Profile for Genomic Data

Remarkable progress in DNA and RNA sequencing have democratized the generation and analysis of genomic data across diverse industry sectors, including biopharmaceutical research, healthcare, consumer ancestry, law...more

[Webinar] How Not to Lose $1M: Preparing for HHS-OIG Info Blocking Enforcement - August 15th, 1:00 pm - 2:00 pm EDT

The US Department of Health and Human Services Office of Inspector General (HHS-OIG) issued a final rule to implement its authority under the 21st Century Cures Act to investigate allegations of information blocking and...more

Special Report - A Million Reasons to Share: OIG’s Final Rule on Information Blocking Enforcement

On July 3, 2023, the US Department of Health and Human Services Office of Inspector General (OIG) published its long-awaited final rule implementing the 21st Century Cures Act provisions authorizing OIG to investigate claims...more

[Webinar] AI Risk Management 101 - June 29th, 12:00 pm - 1:00 pm ET

Healthcare is rapidly changing, with artificial intelligence (AI) and algorithmic models leading the transformation. In recent years, big data and machine learning algorithms have revolutionized our ability to predict...more

Inside the ONC’s Plans to Regulate Health AI: Proposal on Predictive Decision Support Interventions

The Department of Health and Human Services Office of the National Coordinator for Health Information Technology (ONC) published a notice of proposed rulemaking on April 18, 2023, titled “Health Data, Technology, and...more

US Federal Agencies Commit to Regulatory Enforcement of AI Systems

In a recent joint statement, several federal agencies warned that they will commit to enforcing their separate regulations against developers, deployers and users of AI systems, specifically citing civil rights, fair...more

Washington Legislature Passes My Health My Data Act

Washington State’s My Health My Data Act (the Act), which is working its way through the reconciliation process after the Washington Senate and House passed different versions of the Act, is ultimately expected to be signed...more

FDA Issues Draft Predetermined Change Control Plan for Machine-Learning-Enabled Device Software Functions

On April 3, 2023, the US Food and Drug Administration (FDA) published its draft guidance, Marketing Submission Recommendations for a Predetermined Change Control Plan for Artificial Intelligence/Machine Learning...more

California DxF Policies and Procedures Released for Public Comment

On January 17, 2023, the California Health and Human Services Agency (CalHHS) released updated drafts of four policies and procedures (P&Ps) under the California Data Exchange Framework (DxF) to support the implementation of...more

10 Things Providers Should Know About California’s Data Exchange Framework

By January 31, 2023, general acute care hospitals, clinical labs and certain physician organizations and medical groups in California are required to enter into the Single Data Sharing Agreement (DSA) to participate in the...more

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