Since the publication over 20 months ago of the HIPAA Final Omnibus Rule, there has been no shortage of recommendations and advice to health care providers from trade organizations, industry consultants, attorneys and the Office of Civil Rights of the U.S. Department of Health & Human Services (“OCR”) about the steps providers should take in order to achieve HIPAA compliance. Last week marked a final deadline for Omnibus Rule compliance—September 23, 2014, was the date by which covered entities were required to update their agreements with business associates to include certain provisions required under the Rule.
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