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HIPAA Omnibus Rule Reference Chart

Mintz Levin is pleased to provide this section-by-section analysis of the HIPAA Omnibus Rule.

The chart lists provisions of the proposed privacy, security, and enforcement rules mandated by the Health Information Technology for Electronic and Clinical Health Act (“HITECH”) published in a proposed rule on July 14, 2010; the interim final enforcement rule—including HITECH’s new, tiered penalty structure—published on October 30, 2009; and the interim final breach notification rule published pursuant to HITECH on August 24, 2009 (collectively, “Proposed Rules”) and compares them to the same regulatory provisions published on January 17, 2013 as part of the Omnibus Rule (“Final Rule”). Note that this summary does not include revisions under the Genetic Information Nondiscrimination Act (GINA), also published in the Final Rule.

For quick reference, our chart indicates whether or not there were changes between the Proposed Rules and the Final Rule and includes commentary on certain notable provisions.

We hope that this summary will serve as a useful tool as we all begin the process of understanding new requirements under HIPAA.

» View the chart.

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About this Author

Dianne Borque, Health Care, licensure, risk management, attorney, Mintz Levin
Of Counsel

Dianne advises a variety of health care clients on a broad range of issues, including licensure, regulatory, contractual, and risk management matters, and patient care. A large part of her practice involves counseling researchers and research sponsors in matters related to FDA and OHRP regulated clinical research, including patient consent, access to and use of tissue and associated patient information, and the Institutional Review Board process.

She also counsels health care clients and other business entities on the requirements of the HIPAA Privacy Rule and Security Standards,...

(617) 348-1614
Ellen L. Janos, Health care attorney, mintz levin law firm
Member

Ellen specializes in providing regulatory and strategic advice to health care clients of all types, including hospitals, long-term care facilities, hospices, retail pharmacies, PBMs, and pharmaceutical manufacturers.

She also represents companies doing business with, and investing in, health care providers. She represents clients in Medicare, Medicaid, and third-party payor audits and investigations; in the development of corporate compliance programs, HIPAA, privacy and security compliance initiatives; and in the negotiation and implementation of Corporate Integrity Agreements. She...

617-348-1662