As discussed in Part 1 of this series, there are important benefits to licensure compacts, but providers must understand that the benefits come with added compliance responsibilities. Providers who apply for cross-border licensure through PSYPACT, the Counseling Compact, and the Social Work Compact must comply with the laws and rules of the state where the […]
Author Archives: Dena M. Castricone, CIPP/US, CIPM
The demand for licensed behavioral health providers continues to outpace supply, leaving many individuals without timely access to care, especially in underserved and rural areas. To help bridge this gap, Connecticut has joined a growing number of states in adopting interstate licensure compacts for psychologists, professional counselors, and, most recently, clinical social workers. These compacts […]
We understand that the Connecticut state-wide health information exchange, known as Connie, recently sent an email to providers about Connie’s contract documents. The email, entitled “Connie Data Sharing Agreements Follow up,” points to specific language in the state statute and implies that there is a current legal obligation to sign Connie’s contract documents. There is, […]
Yesterday, the Department of Health and Human Services’ Office for Civil Rights (OCR) announced its sixth HIPAA enforcement action of the year. Just two months into 2025 and the total amount of settlements and penalties is already over $5 million. Warby Parker, Inc., a manufacturer and e-retailer of prescription and non-prescription eyewear, was assessed a […]
January was a busy month. Below are some brief summaries of notable developments in health privacy and telehealth. HHS/OCR Issues Proposed Changes to HIPAA Security Rule Just before the new year, the Department of Health and Human Services’ Office for Civil Rights (OCR) issued a notice of proposed rulemaking detailing an overhaul of the HIPAA […]
As Maya Angelou said, “Success is liking yourself, liking what you do, and liking how you do it.” That’s the kind of success I wanted — not the kind with a dollar sign attached, but the kind that makes you love your work. Five years ago, I took a leap of faith and launched DMC […]
Last October, the Drug Enforcement Agency (DEA) and the Department of Health and Human Services (HHS) extended the COVID-era telehealth controlled substance prescribing flexibilities through December 31, 2024. They planned to introduce new standards by this fall. But the agencies need more time to consider all the feedback they have received and, on November 19, […]
Late last week, the Department of Health and Human Services (HHS) released its Model Attestation for use as required under its new final rule for the protection of reproductive health information. I explain the attestation requirement in section D of my blog post on the final rule. On June 18, 2024, I shared my sample […]
In Parts 1 and 2 in this series on the Pixel Problem, I review the original and revised guidance from the Department of Health and Human Services (HHS) on the Use of Tracking Technologies by HIPAA Covered Entities and Business Associates. I noted that HHS’s guidance, even as revised, went too far in determining what […]
On April 26, 2024, just one year after issuing its proposed rule, the Department of Health and Human Services (HHS) finalized changes to the HIPAA Privacy Rule on the protection of reproductive health information (Final Rule). In 91 pages of tiny font in the Federal Register, HHS addressed the 25,000 comments it received and ultimately […]