Howard's blog

Flipping the Presumption: Any disclosure is a breach unless proven otherwise

The Department of Health and Human Service (HHS) and the Federal Trade Commission (FTC) Breach Regulations presume that all unauthorized disclosures are breaches.

Minimum Necessary Follies

Department of Health and Human Services (HHS) uses "minimum necessary" standard to expand breach enforcement. A statement in the preamble to the breach notification interim final regulations puts all non-conforming disclosures of Protected Health Information (PHI) at risk.

Syndicate content