The Omnibus Final Rule

It’s just not good to read “conundrum,” “new regulations,” “administrative and technical challenges,” “impede innovation,” and “contentious issue” all in the same article about HIPAA, the Health Insurance Portability and Accountability Act.  Not after the sloppy, struggling, and insecure roll out of Obamacare.  The Omnibus Final Rule.

There are a few hot button words for me in the JAMA September 18, 2013 article, “The HIPAA Conundrum in the Era of Mobile Health and Communications.”

• mandates
• redefined
• expanded
• now considered
• now required
• can be held criminally liable
• pose technical challenges
• estimated cost $114-225 million for start up
• underestimates compliance costs
• may impose unfunded mandates
• may impede innovation
• in theory. . .
• in practice. . .
• actual security will rely on user’s behavior
• important hurdles
• employing consultants has become the norm
• can be costly
• down stream contractors
• poor guidance
• impose
• shift
• refuse
• trapped
• impassable requirements
• penalized
• landscape is rapidly evolving