Proposed HIPAA Privacy Disclosure Accounting Will Create New Burdens

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