Header graphic for print
HealtHITech Law HIPAA, HITECH and Beyond

Monthly Archives: October 2013

HIPAA Security Risk Analysis: Fact or Fiction?

Posted in Meaningful Use, Security

Leading up to the recent compliance date for the Final HIPAA Rule, much was made about the need for providers to perform a security risk analysis.  Quite a bit of dialogue around the increased security compliance obligations centered on the security risk analysis as a foundational requirement of HIPAA.   Although this is not a new requirement, heightened… Continue Reading

OCR Issues Guidance on Refill Reminder Exception to HIPAA Marketing Rule

Posted in Enforcement, Rulemaking

Prompted by litigation filed by Adheris[1] as well as concerns raised by consumer advocates and health care stakeholders regarding the viability of prescription refill reminder programs under HIPAA’s stricter marketing prohibitions, on September 19, 2013, OCR issued additional guidance regarding the scope of HIPAA’s refill reminder exception.  Notably, OCR also delayed enforcement on this issue… Continue Reading