News & Analysis as of

Covered Entities Guidance Update Department of Health and Human Services (HHS)

Goodwin

Federal Judge Vacates Health and Human Services Pixel Tracking Guidance

Goodwin on

On June 20, 2024, a Texas federal judge ruled that guidance published by the Department of Health and Human Services (the Department) prohibiting covered entities from disclosing information collected by third-party...more

Venable LLP

Federal Court Strikes Blow to HHS Guidance on “Online Tracking Technologies”

Venable LLP on

Last week, a federal district court in Texas issued a decision declaring unlawful and vacating a central component of a guidance document (the Bulletin) from the Department of Health and Human Services (HHS) Office for Civil...more

Shook, Hardy & Bacon L.L.P.

Court Vacates Key Portion of OCR’s Online Tracking Tool Guidance

On June 20, 2024, a federal court vacated key portions of regulatory guidance on the treatment of information collected by online tracking tools. At issue was the U.S. Department of Health and Human Services Office for Civil...more

BCLP

New HHS Guidance on Cookies

BCLP on

On March 18, 2024, the Office of Civil Rights (“OCR”) within the Department of Health and Human Services (“HHS”) updated prior guidance concerning the use of online tracking technologies, including cookies, by Covered...more

Goodwin

In Updated Guidance on Use of Tracking Technologies by HIPAA Regulated Entities, HHS-OCR Takes Expansive View of When Information...

Goodwin on

On March 18, 2024, the U.S. Department of Health and Human Services Office for Civil Rights (HHS-OCR) revised its controversial December 2022 bulletin (the December 2022 Bulletin) regarding the use of tracking technologies by...more

McDermott Will & Emery

OCR Update on Tracking Technologies Provides Little Relief for HIPAA-Regulated Entities

McDermott Will & Emery on

On March 18, 2024, the US Department of Health and Human Services Office for Civil Rights (OCR) issued an update to its December 1, 2022, bulletin titled “Use of Online Tracking Technologies by HIPAA Covered Entities and...more

Holland & Knight LLP

OCR Updates Its Website Tracking Tool Guidance

Holland & Knight LLP on

The U.S. Department of Health and Human Services Office for Civil Rights (OCR) issued updated guidance on March 18, 2024 regarding the use of online tracking technologies by entities and business associates covered by the...more

Jones Day

HHS Releases Guidance on Direct Liability for Business Associates Under HIPAA

Jones Day on

The Situation: On May 24, 2019, the Department of Health and Human Services ("HHS") issued a new fact sheet clarifying business associates' direct liability for violations of the Health Insurance Portability and...more

Latham & Watkins LLP

How Can Healthcare Organizations Prepare for the Next Cyberattack?

Latham & Watkins LLP on

HHS OCR issues checklist, iterative guidance in wake of WannaCry and Petya attacks; Anthem breach settlement provides additional lessons. Key Points: ..Healthcare organizations are particularly vulnerable to ransomware...more

Foley & Lardner LLP

Omnibus 340B Guidance Raises New Issues for Covered Entities

Foley & Lardner LLP on

The Department of Health and Human Services (HHS) released its proposed 340B Drug Pricing Program Omnibus Guidance (Omnibus Guidance) on August 28, 2015. The Omnibus Guidance offers comprehensive – and, in some cases, new –...more

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