Lexology April 21, 2021
The U.S. Department of Health and Human Services Office for Civil Rights’ (“OCR”) 2021 enforcement actions started with a bang, with five Right of Access Initiative settlements in the first three months of the year. Under the Right of Access Initiative, OCR has aimed to support individuals’ right to timely access of their Protected Health Information (“PHI”)[1] and has targeted covered entities’ non‑compliance with fulfilling HIPAA right of access requirements. While the emerging enforcement trends from this Initiative are particularly relevant for covered entities, they also have important implications for business associates, especially with respect to contractual obligations and liabilities under business associate agreements (BAAs). Below, we analyze these trends and implications and provide our recommendations for how business associates...
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