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 […]
It’s been a while since my last post – nearly 3 months. Riddled with guilt and with very little extra time on my hands, I turned to ChatGPT. I asked it to “draft a blog post for DMC Law, LLC apologizing for not writing a blog post in a while.” The text below is from […]
In June 2022, several media outlets broke a story about hospitals using a website technology that caused patient data to be sent to Facebook known as Meta Pixel. Specifically, the investigation found that 33% of the top 100 hospitals tracked user activity tied to scheduling appointments and, because the hospitals used Meta Pixel technology on […]
One year after Connecticut became the fifth state in the nation to adopt a consumer data privacy law, the state Legislature emerges again as a data privacy leader by adding protections for consumer health data and minors to the Connecticut Data Privacy Act (“CTDPA”). With unanimous votes in the state House and the Senate, An […]
VIA Electronic Submission at www.regulations.gov RE: HIPAA Privacy Rule to Support Reproductive Health Care Privacy, NPRM, RIN 0945-AA20 Dear Department of Health and Human Services, Thank you for the opportunity to submit comments on the Notice of Proposed Rule Making regarding proposed modifications to the HIPAA Privacy Rule to Support Reproductive Health Care Privacy (NPRM). […]
On May 18, 2023, the day after the Federal Trade Commission (FTC) announced only its second enforcement action under the Health Breach Notification Rule (HBNR) in 13 years, it released proposed changes to “strengthen and modernize” the rule. Those proposed changes will substantially expand the scope of the HBNR. Congress, however, never intended that the […]
It’s been a week filled with last-minute government pivots to avoid interruptions of care. Literally less than 12 hours before the end of the public health emergency (PHE), Connecticut’s Department of Social Services (CT DSS) released revisions to its telehealth guidance for Medicaid recipients. Earlier this week, the Drug Enforcement Agency also issued a last-minute […]
You could almost hear the collective sigh of relief from healthcare providers around the country on May 9, 2023. Two days before the end of the public health emergency (PHE), the Drug Enforcement Agency issued a Temporary Rule that extends current flexibilities for telehealth prescribing of controlled substances for another six months. The Temporary Rule […]
Earlier this year, we learned that the U.S. Department of Health & Human Services’ (HHS) Office for Civil Rights (OCR) would propose changes to HIPAA to protect reproductive health information in the wake of the 2022 Dobbs v. Jackson Women’s Health Organization decision. Since learning about the impending proposal, many of us speculated on OCR’s […]
On March 27, 2023, Connecticut’s Department of Social Services (CT DSS) published post-pandemic guidance regarding the delivery of telehealth services. Important subjects in the guidance include written consent, provider location, documentation requirements and the re-introduction of the established patient requirement for some services. This guidance is effective on May 12, 2023, the day after the […]