Erin Dunlap Provides Insight on Overturned HIPAA Penalty for Healthcare Risk Management

Erin Dunlap Guides Healthcare Risk Management Readers Through Revising HIPAA Patient Access Policies If Proposed Changes are Finalized

Following proposed changes to the HIPAA Privacy Rule from the U.S. Department of Health and Human Services (HHS) that left health plans and covered healthcare providers wondering how to prepare, Healthcare Risk Management turned to Erin Dunlap for insight. Explaining that patient access will be a key area of focus, Erin outlined eight ways patient access policies will need to be revised if HHS finalizes the changes. Erin also noted that revisions to a covered entity’s notice of privacy practices will also be necessary if the changes are finalized and urged plans and providers to prepare and budget for significant policy work and training. A nationally recognized expert in health care data privacy and security, Erin regularly advises organizations working in the health care space on a...

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Erin Dunlap Provides Insight on Overturned HIPAA Penalty for Healthcare Risk Management

Erin Dunlap Provides Insight on Overturned HIPAA Penalty for Healthcare Risk Management

When the Fifth U.S. Circuit Court of Appeals overturned a $4.3 million civil monetary penalty imposed on the University of Texas M.D. Anderson Cancer Center by the U.S. Department of Health and Human Services (HHS), Healthcare Risk Management asked health care data privacy attorney Erin Dunlap to explain how the decision may impact HIPAA covered entities and business associates. Erin called the decision a “game changer,” particularly in how entities subject to HIPAA will view HIPAA’s encryption rule, evaluate a loss of protected health information (PHI) and engage with HHS in setting investigations.  Erin specifically highlighted the Fifth Circuit’s position that the encryption specification was not a strict liability rule and perfection or ‘bulletproof protection’ is not the standard.  This is helpful for HIPAA covered entities...

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