Lexology February 27, 2025
Bradley Arant Boult Cummings LLP

In this week’s installment of our blog series on the U.S. Department of Health and Human Services’ (HHS) HIPAA Security Rule updates in its January 6 Notice of Proposed Rulemaking (NPRM), we are exploring the justifications for the proposed updates to the Security Rule. Last week’s post on the updates related to Vulnerability Management, Incident Response & Contingency Plans can be found here.

Background

Throughout this series, we have discussed updates to various aspects of the Security Rule and explored how HHS seeks to implement new security requirements and implementation specifications for regulated entities. This week, we discuss the justifications behind HHS’s move and the challenges entities face in complying with the existing rule.

Justifications

HHS discussed multiple reasons for...

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