[ Friday, October 10, 2014 ]
Accounting for Disclosures: Have you been worrying about how to comply with the accounting for disclosures rule that HHS published way back in 2011? No? Hell, even I'd forgotten about it, even though I gave quite a few speeches and webinars about it. It's a mess, and raised all kinds of issues based on who "touched" the file, not just to whom it was disclosed. It was to have become effective January 1, 2015. However, HHS has just announced that they will delay the effectiveness and reopen the rule for comment. That's the right thing for them to do.
Jeff [11:39 AM]
People rarely ask for accountings of disclosures, and often do so for (illegitimate) aggressive or litigious purposes. So making the industry jump through hoops for such a rare reason is sensible.
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