Given the track record for HIPAA regulations estimated versus actual
dates over the past almost six years, I recommend a policy of ...
Don't Guess -- Don't Tell.
Dave Feinberg
Rensis Corporation [A Consulting Company]
206-617-1717
[EMAIL PROTECTED]
----- Original Message -----
From: "Barrick, Ivan" <[EMAIL PROTECTED]>
To: <[EMAIL PROTECTED]>; <[EMAIL PROTECTED]>;
<[EMAIL PROTECTED]>
Sent: Friday, June 14, 2002 4:22 AM
Subject: RE: Privacy Mods... When will they go into effect.....?
Far too optimistic!
Ivan
-----Original Message-----
From: [EMAIL PROTECTED]
[mailto:[EMAIL PROTECTED]]
Sent: Thursday, June 13, 2002 6:21 PM
To: [EMAIL PROTECTED]; [EMAIL PROTECTED]
Subject: Privacy Mods... When will they go into effect.....?
Hi All,
The proposed modifications to privacy rule were open for public
comment for 30 days, through April 26, 2002. I haven't found
anything on how long HHS will review the comments that were gathered
in those 30 days. My guess is that it will take 60 to 90 days to
review the comments and publish a final Reg that modifies the Privacy
Rule. Then it goes to the Office of Management and Budget for final
review... probably around 30 days.
Therefore we should see the final Privacy Modification Reg between
the end of June and the end of July. If the Office of Management and
Budget holds to their normal timeline, they will approve
implementation between the end of July to the end of August.....
Of course, all the scenarios assume that there is no delay for
Political or other reasons.... and Sen. Kennedy is/was holding
hearings on Medical Privacy. Bottom line, HHS is better known for the
dates that it misses than the dates that it makes.....
Question: Are the scenarios above accurate and probable? Am I out in
left field? Have they already been approved (not likely, since I just
got off the Office of Management and Budget website on pending rules
under review)? What happens if the modifications are NOT final before
April 2003? What's my risk if I implement Privacy with the
modifications, even though the mods aren't yet final?
Jim Moores - HIPAA Team Leader - Privacy
Antares Management Solutions
23700 Commerce Park Road
Beachwood, Ohio 44122-5832
[EMAIL PROTECTED]
Phone: (216)292-1605
Fax: (216)292-1619
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