In this episode of 1st Talk Compliance, Kevin Chmura is joined by Rachel Rose, JD, MBA, to discuss the HIPAA Privacy Rule to Support Reproductive Healthcare Privacy, passed in 2024. With the reproductive healthcare landscape being very dynamic, this new rule has already passed one compliance date, with a second important date coming in February 2026. Tune in to learn about this new rule, and what it means in terms of reproductive health, patient privacy, and the legality between different states. In addition, learn some best practices for implementing the requirements of this rule into your practice. On June 18, 2025, The U.S. District Court for the Northern District of Texas - Amarillo Division (Carmen Purl, et al v. United States Department of Health and Human Services, et al., Case No. 2:24-cv-228-Z (N.D. Tex.)), issued an order vacating the HIPAA Privacy Rule to Support Reproductive Health Care Privacy, published on April 26, 2024, which amended the HIPAA Privacy Rule (Reproductive Health Rule). The decision left intact amendments to the HIPAA rule regarding certain Notice of Privacy Practice provisions pertaining to substance use disorder regulations, which need to be adhered to by early 2026. Kevin Chmura Rachel, thank you for joining us. Appreciate you joining us and looking forward to a timely discussion. Rachel V. Rose Thank you, Kevin, for having me, as well as to Panacea and First Healthcare Compliance, it's always my pleasure to coordinate and converse with you on our favorite healthcare compliance topics. Kevin Chmura And it's always great having you helping us with this and your expertise is invaluable. And you helped us and were the contributor, really writer, of an e-book on this particular subject that will be released very soon. Really this podcast is somewhat of a companion piece to that. And so what we're talking about today is the HIPAA privacy rule to support reproductive health care privacy, passed in 2024. Reproductive health is a prominent and evolving topic within the healthcare policy landscape. It really, major changes have come down in recent years, and so there's just a ton. So we thought it would be great to publish a book to get everybody up to speed and, but moreover, this podcast is an opportunity for people to hear directly from the person who helped us develop that. And that is Rachel. So, Rachel, I wonder, can you just start off by giving us a synopsis of the 2024 Final Rule, maybe some key terms we should be thinking about? Rachel V. Rose Sure. As you mentioned, Kevin, the reproductive healthcare landscape is very dynamic and the rule itself was issued on April 22nd of 2024 with an effective date of June 25th of 2024. And basically what an effective date does is to start the clock running as to when certain requirements need to be implemented. In this particular rule, which I will refer to as the HIPAA Reproductive Rule, has two prongs of compliance dates. The first already passed and that had to be done by December 23rd, 2024. And for your clients who were with First Healthcare Compliance or Panacea at the time, they were able to access FAQs. And the first prong of the requirements really addressed every applicable item that I'll run through, with the exception of the notice of privacy practices. Now, for anyone who's been in the healthcare sector for a long time, and for anyone who goes to the doctor, a dentist or even a pharmacy to pick something up, we all know we have to sign the HIPAA authorization form, and then covered entities are required to post their notice of privacy practices. So the updated privacy practices, which need to include some of the reproductive health requirements among other items, does not need to be done until February 16 of 2026. So this is similar to the staggering of the compliance dates which we saw with the Final OmnibusRrule, which was published in the Federal Register,
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