By the EHR Association Privacy & Security Workgroup

This three-part blog series shares the EHR Association’s stance on OCR’s proposed changes to the HIPAA Security Rule. Part one focused on our overarching concerns and issues with proposed definitions. Part two focuses on several of the proposed standards.

Our analysis of proposed changes to the existing HIPAA Security Rule, released as HIPAA Security Rule to Strengthen the Cybersecurity of Electronic Protected Health Information, revealed a mixed bag of positive changes and areas of concern. In the first installment of this blog series, we noted the EHR Association’s appreciation for its enhancements to the cybersecurity baseline. However, we expressed concern about the resources and costs required for regulated entities to comply with the overhauled mandates. We also reviewed the feedback we shared with OCR on its proposed changes to key definitions.

In this installment, we highlight our concerns with several of OCR’s proposed expectations, drawing attention to the need for greater clarity and offering recommendations to ease compliance burdens while achieving intended outcomes.