On June 24, 2025, Connecticut’s governor signed into law a public health act (the Act) that includes updates to the law governing the statewide health information exchange, commonly known as Connie. While these updates are less substantial than those enacted during the 2024 spring legislative session, they represent meaningful progress on issues that matter to many healthcare providers.
A New Study on Important Issues
Section 47 of the Act adds a new provision that requires the Commissioner of the Office of Health Strategy (OHS) to conduct a study to address the following:
- Granular Patient Consent – Evaluate options that would allow patients to control what specific health information is shared with Connie, including the operational and financial impact of implementing such options.
- Simplified Participation Agreements – Assess the feasibility of allowing providers to participate in Connie using only a standard HIPAA business associate agreement, in place of Connie’s current extensive agreement.
- Improved Opt-Out Process – Review existing patient opt-out procedures and consider ways to enhance transparency and simplify the process.
- Health Data Landscape – Summarize the state’s current health data sharing practices, existing privacy protections, and the benefits of provider access to patient information.
The Commissioner must submit a report on the findings to the Public Health Committee by September 30, 2026.
Changes to Existing Provisions
Section 48 of the Act makes several clarifying amendments to Conn. Gen. Stat. § 17b-59e:
- Not Actively Practicing in CT – Healthcare providers licensed in Connecticut but not actively practicing in the state are not required to connect to Connie.
- Breach Responsibility – Connie is explicitly responsible for any required notifications or mitigation in the event of a data breach or cyber incident – this is a meaningful protection for healthcare providers.
- Subpoena Response – Connie is prohibited from disclosing protected health information in response to a subpoena unless the disclosure fully complies with all applicable state and federal medical records laws. The hope is that this provision will ensure that Connie safeguards reproductive health and gender-affirming care information in accordance with the same legal standards that apply to providers and insurers in Connecticut.
Does This Change What Providers Need to Do Now?
No. Providers still have 18 months from the date OHS publishes its official policies and procedures to connect to Connie and complete onboarding — including signing any required agreements. As of the date of this post, OHS has not yet published those policies or procedures.
What Should Providers Do Now?
Continue to wait. Do not sign any Connie contract documents yet. The required documents and scope of participation may change with OHS policies and procedures and/or future legislative changes.
As always, DMC Law will post any further updates.