WilmerHale Partner Kirk Nahra addresses the New HIPAA NPRM. Following a pattern of familiarity for health lawyers, the Department of Health and Human Services (HHS) has released a substantial Notice of Proposed Rulemaking (NPRM) in December at the end of an administration. This NPRM reflects two key issues of concern to the Office for Civil Rights (OCR) in its current incarnation: improving patient access to health information (a goal presumably shared by a new administration) and expanding opportunities for increased information sharing in specific contexts (primarily focused on coordinated care and sharing with social service organizations).
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