During the final hours of the Connecticut legislative session, the state Senate passed House Bill 5198, solidifying changes to the state’s telehealth law, sending the bill to the Governor for signature. This bill adopts some of the temporary pandemic-era changes to the telehealth law, such as permitting audio-only telehealth and prohibiting insurers from paying less […]
Author Archives: Dena M. Castricone, CIPP/US, CIPM
Within the last week, both chambers of the Connecticut Legislature passed Senate Bill 1, which includes provisions revising the law governing the Statewide Health Information Exchange known as Connie (sections 21-24). Once the Governor signs the bill, it will take effect on July 1, 2024. In summary, the bill makes clear that healthcare providers are […]
In December 2022, the Department of Health and Human Services’ Office for Civil Rights (OCR) released “guidance” on the use of tracking technologies, which took an overboard approach to the use of basic website analytics tools (2022 Guidance). Courts criticized OCR’s 2022 Guidance, and last fall, the American Hospital Association sued OCR, alleging agency overreach. […]
Buckle up. The 42 CFR Part 2 enforcement ride is about to begin. In the 2020 CARES Act, Congress directed that the civil and criminal penalties under the Health Insurance Portability and Accountability Act (HIPAA) apply to the federal regulations protecting substance use disorder (SUD) records. The Department of Health and Human Services (HHS) issued […]
As discussed in Part I of this series, Congress amended the federal law protecting the confidentiality of substance use disorder (SUD) records as part of the 2020 CARES Act and directed the Department of Health and Human Services (HHS) to revise the related regulations at 42 CFR Part 2. Congress’s goal was to align the […]
In the 2020 Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Congress amended the federal law protecting the confidentiality of substance use disorder (SUD) records to facilitate the coordination of care in an effort to combat the opioid epidemic. It also directed the Department of Health and Human Services (HHS) to revise the related […]
The landscape of enforcement actions related to the Health Insurance Portability and Accountability Act (HIPAA) provides valuable insights into enforcement priorities, which can vary from year to year. In fact, 2023 was very different than 2022 (“The Year of the Dentist”). Specifically, in 2023, there was a notable decrease in patients’ right of access matters […]
It’s been quite the year! Last year’s blog post on Connie was subject to five revisions between December and April, reflecting the challenges of gathering accurate information about Connecticut’s Health Information Exchange and its operation. Fortunately, there are some promising updates to share. Early 2023 The start of 2023 was marked by confusion and frustration […]
We are thrilled to announce that DMC Law, LLC is celebrating its fourth anniversary! It has been an incredible journey, and we truly are grateful for the trust and support of our clients, colleagues, and friends. Over the past four years, DMC Law, LLC has been dedicated to providing exceptional legal services to healthcare providers […]
After holding two listening sessions in September, during which the agency heard from stakeholders including practitioners, the Drug Enforcement Agency (DEA) extended the COVID-era telehealth prescribing flexibilities again. The issue of telehealth prescribing of controlled substances after the end of the public health emergency (PHE) has been on a bit of a rollercoaster ride. The […]