The U.S. Department of Health and Human Services Office for Civil Rights (OCR) issued guidance regarding covered entities’ and business associates’ use of tracking technologies (the Guidance). As discussed in greater detail below, the Guidance reveals OCR’s position that an IP address is not just an identifier but is itself individually identifiable health information (IIHI) … Continue Reading
Vendor-caused incidents continued to surge in 2021. Nearly 20 percent of the total incidents we handled last year were caused by vendors, with more than half requiring notification. As in prior years, vendor incidents involved phishing schemes and inadvertent disclosures but primarily resulted from ransomware attacks on the vendors’ systems. These ransomware attacks often involved … Continue Reading
On Monday, the U.S. Department of Health and Human Services (HHS) issued what it calls “transformative” rules that will govern how healthcare providers, insurers and technology vendors must design their systems to give patients safe and secure access to their health data. Issued by two different agencies within HHS – the Office of the National … Continue Reading