Comments to HIPAA Privacy Rule

Health Law Section Submits Comments to HIPAA Privacy Rule and the National Instant Criminal Background Check Systems

The American Bar Association Health Law Section has filed comments in response to the proposed rule issued by the Office for Civil Rights, Department of Health and Human Services (“HHS”) to modify the Health Insurance Portability and Accountability Act of 1996 Privacy Rule.

The comments were prepared by a working group of the Health Law Section’s eHealth, Privacy, and Security Interest Group. The contributors to these comments from the working group are Catherine A. Barrett, Anjali Dooley, Amy Fehn, Jamie Levin, Elaine Zacharakis Loumbas, Rich Marotti, Deborah Moldover, Caitlin Monjeau, Sue Nolan, Andrew Robertson, Robert Schwartz, Konrad Trope, and John Wright.  In addition, Linda A. Malek served as a reviewer of the Task Force’s work and participated in the preparation of the final comments. 

The final comments were approved by the Section’s Council on March 2, 2014 and submitted to HHS on April 9, 2014.