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Hogan Lovells Publications
"HHS releases proposed rule on accounting of disclosures." Health & Privacy Alert, Hogan Lovells, 02 June 2011

Barbara Bennett, Melissa K. Bianchi, Nadine P. Peters, Marcy Wilder

The Department of Health and Human Services (HHS) published on 31 May a proposed rule modifying the HIPAA Privacy Rule's accounting of disclosures requirement. The proposed rule would provide individuals with a new right to receive a written "access report" that describes uses and disclosures of their protected health information (PHI) made through an "electronic designated record set." The proposed rule also makes a number of changes to the existing accounting of disclosures requirements.

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