Lexology September 23, 2024
Gordon Feinblatt LLC

In December 2022, the Office of Civil Rights (OCR) issued a bulletin (2022 Bulletin) warning Health Insurance Portability and Accountability Act (HIPAA) covered entities and business associates about the use of online tracking technologies, that are often part of an entity’s website or mobile application.

In the 2022 Bulletin, the OCR stated that when individually identifiable health information (IIHI), such as the individual’s medical record number, home or email address, dates of appointments, IP address or geographic location, is collected through a regulated entity’s website or app, that IIHI will generally be PHI, even if the individual does not have a relationship with the regulated entity and the IIHI does not include any treatment or billing information.

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Topics: Govt Agencies, Health System / Hospital, HIPAA, Provider
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