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HHS’s Enforcement Discretion Notice May Signal More Potential Violations

The HHS Office for Civil Rights (“OCR”) issued a notice in the Federal Register regarding its Enforcement Discretion (84 Fed. Reg. 18151) on April 30, 2019. HHS announced that HHS will now apply a different cumulative annual...more

Deal Breaker – Cyber Security Risk in Health Care Transactions

Health care organizations’ lack of compliance with the data privacy and security requirements of both state laws and the Health Insurance Portability and Accountability Act (“HIPAA”) Privacy, Security and Breach Notification...more

Health Care Industry Must be Mindful of ‘Information Blocking’

Under the 21st Century Cures Act (Cures Act), the Health and Human Services (HHS) Secretary is mandated to have promulgated regulations by Dec. 13, 2017 that, among other requirements, prohibit “information blocking” as a...more

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