Lexology June 23, 2025
Key takeaways
- U.S. District Court for the Northern District of Texas vacated nearly all of the 2024 amendments to the HIPAA Privacy Rule that created special protections for reproductive health care information, finding that HHS exceeded its statutory authority.
- The court determined that the Reproductive Health Privacy Rule improperly limited state child abuse reporting laws, impermissibly redefined key statutory terms like “person” and “public health,” and violated the “major questions doctrine” by regulating politically significant areas without clear congressional authorization.
- As a result of the ruling, HIPAA covered entities and business associates must revisit and potentially revise policies, procedures, training programs, business associate agreements, and notices of privacy practices that were updated to comply with the now-vacated rule.
- Despite...







