[ Friday, January 18, 2013 ]


First nugget from the Omnibus Rule: The effective date of the rule for compliance purposes is 180 days after publication.  I think the publication date will be Tuesday, January 22.  The 180 day compliance period will probably appear on all new HIPAA regulations.  However, for historical purposes, the regulations will retain the April 2003 and 2005 compliance dates for the Privacy Rule and Security Rule, respectively.

Oops, spoke too soon.  "Effective date" will be March 26, 2013, and compliance date will be 180 days after that.  The 180 day lag doesn't apply to the enforcement rule, which makes sense, because those aren't standards or implementation specifications that covered entities must implement or meet.

Jeff [10:19 PM]

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