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Jesse C. Vivian, RPh, JDProfessor, Department of Pharmacy PracticeCollege of Pharmacy and Health SciencesWayne State UniversityDetroit, MichiganA new self reporting rule has gone into effect that requires health care providers to give notice to specified persons and entities when a breach of the Health Insurance Portability and Accountability Act of 1996 HIPAA privacy rules occurs. 1 The Department of Health and Human Services HHS issued rules on August 24, 2009, that took effect on September 23, 2009. However, enforcement of the rules, with applicable sanctions, will not occur until February 10, 2010. In the meantime, entities subject to the privacy rules are expected to develop voluntary compliance policies and work with HHS to ensure that those procedures meet the intent of the law. 2 As an aid to helping organizations understand the intricacies of the rules, on August 29, 2009, HHS issued the HITECH Breach Notification Guidance. 3 Provisions of this Guidance are discussed below. The breach notification regulations were mandated by the Health Information Technology for Economic and Clinical Health Act HITECH, which was part of the American Recovery and Reinvestment Act of 2009 ARRA signed on February 17, 2009the so called federal stimulus bill. 4 Title XIII of HITECH includes $22 billion to advance the use of health information technology. 5 Unauthorized access to medical records and subsequent disclosure to media outlets have been the subject of much publicity, especially when celebrities are involved. When the now deceased actress Farah Fawcett was treated at the University of California Los Angeles UCLA Medical Center for cancer, her records showed up in the National Enquirer and Globe tabloids even before she told family and friends about her condition.
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