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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