In our November 30, 2011 and March 7, 2012 posts, we discussed the HHS Office for Civil Rights (OCR) audit pilot program, which began in November 2011 and is expected to conclude in December 2012. The audit program has been developed pursuant to the requirements of the HITECH Act. Under the audit pilot program, OCR conducted an […]
HIPAA/HITECH Act Privacy Rule Delayed?
Despite recent indications from HHS and the Director of HHS’s Office for Civil Rights (OCR) that the HIPAA/HITECH Act Omnibus Final Rule is extremely close to publication, the White House’s Office of Management and Budget (OMB) has extended its review of the rule under Executive Order 12866. As we recently commented, in a report published […]
Vermont and Connecticut Add Attorney General Notification to Data Breach Notice Statutes
In what appears to be a growing trend, Vermont and Connecticut have added a requirement to separately notify the states’ Attorney General’s office of a data breach involving the personal information of Vermont and Connecticut residents. Last year, California amended its data breach notification statute with a similar requirement. Vermont’s amended Security Breach Notification […]
HIPAA/HITECH Act Privacy Rule Coming in July 2012?
In March, we reported that the U.S. Department of Health and Human Services (HHS) had submitted the HIPAA/HITECH Act Omnibus Final Rule to the Office of Management and Budget (OMB) for review under Executive Order 12866, and that OMB had up to 90 days to review the rule under the Executive Order. In HHS’s May 2012 […]
Illinois Joins Maryland in Limiting Employer’s Access to Employee Facebook Pages
On May 23, Illinois followed in Maryland’s footsteps to become the second state to pass a law prohibiting employers from asking employees or job applicants for their passwords to social networking websites. Although the Illinois governor must still approve the legislation before it goes into effect, approval seems imminent given the Illinois Senate’s unanimous passage […]