Expansive HIPAA Privacy and Security Changes

One of ARRA's objectives is to invest in improving health information technology and promoting the use of electronic health records with the goal of reducing health care costs, streamlining the health care system and reducing medical errors. To address the privacy and security concerns which arise from the increased use of technology in this arena, ARRA includes a number of provisions which amend, clarify or expand the administrative simplification provisions of Title II of the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), and the privacy and security regulations issued by the Department of Health and Human Services ("HHS"). Most of these changes are effective 12 months after ARRA's enactment date, but as discussed below, there are several provisions with an earlier or later effective date.