On January 25th, the U.S. Department of Health and Human Services published major modifications to the HIPAA privacy, security, and breach notification rules in the Federal Register. These rules will significantly impact many financial institutions that service health care providers and health plans, potentially making them directly liable for penalties under HIPAA for noncompliance. This may include financial institutions that handle accounts receivable for health care entities, act as a “health care clearinghouse” with respect to handling health care claims or remittance advice, and (at least arguably) those that provide lockbox services to health care providers and health plans.
DWT partners Adam Greene and Becky Williams will be presenting a complimentary webinar detailing the impact of HIPAA on business associates and their subcontractors on January 30 at 10 am PST/1 pm EST. Registration is available at http://www.dwt.com/The-Brave-New-World-of-Business-Associates-Davis-Wright-Tremaine-Webinar-01-30-2013/. We invite all potentially affected parties to attend.