News, Insights & Events

COVID-19 and HIPAA

March 25, 2020

Ruth T. Griggs

Sands Anderson PC

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Richmond, Virginia

The United States Department of Health and Human Services (HHS) Office of Civil Rights (OCR) has recently issued guidance regarding disclosures of patient health information to law enforcement, first responders, and public health entities. The guidance is available here. HIPAA already has many provisions which permit disclosures in a variety of circumstances that HIPAA covered entities and business associates may encounter, but the HHS/OCR guidance offers sample scenarios which help clarify permissible disclosures under existing regulatory provisions.

Remember that HIPAA also applies to Business Associates of HIPAA covered entities. This guidance may be particularly helpful for Business Associates who are less experienced with HIPAA.