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NAID Submits Official Comments Supporting HIPAA Modifications

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On Friday, September 10th, NAID submitted its official comments on Health and Human Services’ proposed modification to HIPAA to implement the requirements of Health Information Technology for Economic and Clinical Health (HITECH).

According to NAID CEO Bob Johnson, “It’s good to be in a position of supporting the recommendations.  Our primary purpose for commenting was to defend what HHS is proposing from forces that might object from more intense scrutiny.  It’s like having the high ground in an uphill battle.  It is nice and defendable.”

NAID did offer suggestions for clarifying that on-site service providers are business associates, fitting the primary qualifier of “access to PHI” and to confirm that paper generated from electronic sources is covered by the Security Rule, which would be consistent with other HHS precedents.

The NAID comment is posted along with all other comments on the HHS website.  HHS will respond to all comments and issue a final ruling in a few months.

Click here to go to HHS comments page on the proposed HIPAA modifications, then click the box marked “Public Comment.”  There were 551 total comments submitted.