HEALTH REFORM: HIPAA Omnibus Rule’s Impact on Notices of Privacy Practices

This health reform alert summarizes the key changes to the Notice of Privacy Practices (“NPP”)[1] requirements in the revised Health Insurance Portability and Accountability Act (“HIPAA”) regulations (the “Omnibus Rule”)[2] as well as what covered entities need to do to be compliant.[3] Because many covered entities may have modified their NPPs based on the Notice of Proposed Rulemaking issued on July 14, 2010 (“NPRM”),[4] this alert also details the similarities and differences between the NPRM and the Omnibus Rule related to NPPs. In addition, Table 1 of this alert provides a quick summary of the NPRM proposals adopted—or not adopted—by the Omnibus Rule.