Our partner Keith McMurdy posted a timely summary of the requirements of the HIPAA Omnibus Rule for employers and benefit plan sponsors at his Employee Benefits Legal Blog.  It is reproduced below:

Lost in the Shuffle: The September 23 HIPAA Notice Requirements

By Keith R. McMurdy on September 6, 2013Posted in Plan Administration,

The HIPAA/HITECH Omnibus Rule that appeared in the January 25, 2013 Federal Register contained this cryptic and apparently contradictory statement:

DATES: Effective date: This final rule is effective on March 26, 2013.

Compliance date: Covered entities and business associates must comply with the applicable requirements of this final rule by September 23, 2013.

 

What

CMS should improve its oversight of its electronic health record incentive program, according to a report by the Office of Inspector General released this month.   The government watchdog agency faults CMS for both inadequate prepayment safeguards and insufficient postpayment monitoring of recipients of federal funding intended to help cover the costs of adoption and implementation

Early EHR adopters, mark your calendars:  CMS will begin accepting registration for participation in the Medicare EHR incentive program beginning January 3,  2010.   CMS will post a link to the registration process on its Registration and Attestation page on January 3.  The sooner you apply, the sooner you can begin to qualify for the $44,000 in additional Medicare

With a press conference featuring top officials including HHS Secretary Kathleen Sibelius, the Office of Civil Rights rolled out a 234-page Notice of Proposed Rulemaking on July 8, 2010. The full text is here. The agency described the proposed rulemaking as including significant modifications to the HIPAA Privacy, Security and Enforcement rules, as well as resources

Ambulance-chasing meets the age of electronic records.  The husband and wife team of Ruben E. Rodriguez and Maria Victoria Suarez  have been charged with conspiring with an ambulance company worker to steal personal identification information of individuals transported by Randle Eastern Ambulance Service, Inc., d/b/a American Medical Response (“AMR”) and sell the information to various South

 The Health InformationTechnology for Economic and Clinical Health Act or the “HITECH Act”  provides incentive payments for adoption and meaningful use of HIT and qualified EHRs.  CMS published a proposed rule defining "meaningful use" on December 30.  It’s 566 double-spaced pages long, and can be found here:  http://www.federalregister.gov/OFRUpload/OFRData/2009-31217_PI.pdf.  

An eligible physician or other