Lexology November 2, 2021
Dinsmore & Shohl LLP

Questions abound as to whether HIPAA comes into play when COVID-19 vaccination information is provided to employers. Recently, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) issued clarifying guidance on the applicability of the HIPAA Privacy Rule in the context of COVID-19 vaccination information provided to employers.

This guidance is to remind the public that the HIPAA Privacy Rule generally does not apply to employers or employment records, which includes health care providers in their roles as employers. The HIPAA Privacy Rule applies only to health care providers and health plans (and their business associates) in their roles as health care providers or payers – not in their roles as employers. The guidance emphasized...

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Topics: Govt Agencies, Healthcare System, HHS, HIPAA, Patient / Consumer, Provider, Public Health / COVID
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