June 16, 2011
Covered entities and business associates should prepare for new disclosure
accounting requirements under the HIPAA Privacy Rule. In a Notice issued by the
Department of Health and Human Services, the Proposed Rule provides patients
with a right to an “accounting of disclosures” and the right to obtain an
“access report” for electronic health records.
McGuireWoods has prepared a white paper,
Proposed HIPAA Privacy Disclosure Accounting, addressing the following:
- Current Law
- Expansion of Accounting Required by the HITECH Act
- Accounting of Disclosure Requirements under the Proposed Rule
- Access Reports Required by Proposed Rule
- What Covered Entities Should Do
- What Business Associates Should Do
- Unresolved Issues under the Proposed Regulations
Comments on the Proposed Rule are due by August 1, 2011, and may be submitted
at http://www.regulations.gov.