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July 27, 2014

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 the Author

Dianne J. Bourque, Health Care Attorney, Mintz Levin Law Firm
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

About the Author

Kimberly J. Gold, Health Care Attorney, Mintz Levin Law Firm
Associate

Kimberly's practice focuses on regulatory and transactional matters, including compliance, privacy and security, mergers and acquisitions, financings, licensing, and reimbursement.

Kimberly has extensive experience in the areas of privacy and security of patient information under HIPAA and state laws. She has prepared compliance programs, privacy policies, business associate agreements, and counseled clients on breach notification requirements. She also represents clients in the health information technology area and has counseled mobile app companies on privacy and FDA...

212-692-6706
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

About the Author

Project Analyst

James attended Boston College and received his BA in History and Political Science. His senior honors thesis investigated the polarization of America’s two main political parties through an historical analysis of the national health care debate since 1970, which received the distinction of a Scholar of the College project from Boston College.

In addition to conducting his own research, James worked with several professors on various projects, including with Prof. Kay Schlozman of the Political Science Department at BC and Sidney Verba of Harvard on their recently released book...

617-542-6000

About the Author

Stephanie Willis, Health Care, Attorney, Mintz Levin, Law Firm
Associate

Stephanie primarily works with health care clients, including clinical laboratories, renal dialysis providers, and hospitals to comply with state and federal laws and regulations governing licensure, reimbursement, health care fraud and abuse, telemedicine, and health information privacy requirements.

She has used her past experience as an Associate Counsel in the Office of the Inspector General for the Department of Health and Human Services and as an intern at various Massachusetts health care agencies to help clients achieve positive results.

202-434-7437

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