For Clarity’s Sake: Feedback on Recent OCR Recommendations

New Rule OCR Recommendations Clarified

OCR just signaled where HIPAA enforcement is heading and healthcare organizations should take note. In an April 23, 2026 news release re four ransomware investigation settlements, the OCR outlined 8 cybersecurity recommendations for covered entities and business associates. Learn more>

You Have Time, HIPAA’s Security Rule Hasn’t Changed Yet

NPRM Security Rule proposed

You’re fine, really. No need to panic. Yes, the NPRM is [finally] progressing. BUT – it’s not yet time to overhaul HIPAA Security Policies & Procedures, or buy new tools. Read my latest article to learn why (and DM me if you’d like a free copy of my latest webinar material relating to the NPRM). Read on to learn more.

Proposed HIPAA Rule Changes – Presentation Clip

HIPAA Changes HCCA webinar

I recently had the opportunity to present an HCCA continuing education webinar on the NPRM related to the proposed changes to the HIPAA Rule. I invite you to watch the 5-minute clip here, where I talk about proposed patching expectations and touch on the Security Risk Analysis’s emphasis. Here at Apgar and Associates, we’re scheduling … Read more

If the NPRM Becomes Law, Will Your Security Risk Analysis Hold Up?

NPRM Carrot with Stick Security Risk Analysis

Let’s look at the historical approach from OCR when it comes to HIPAA Security Rule enforcement. Since 2005, the Office for Civil Rights (OCR) has relied on the carrot approach rather than the stick. The existing Security Rule defines risk analysis as the first required implementation of the first required standard. But the existing language … Read more

How is OCR handling Women’s Reproductive Healthcare challenges as relates to PHI?

OCR PHI and reproductive health

With every new headline about women’s reproductive health, providers and patients have been left wondering what’s next legally. Will they be protected or prosecuted? The answer could be down to interpretation of HIPAA’s Privacy Rule. To that end, OCR’s taken the position of clarification and strengthening PHI protections from the HIPAA perspective. On April 12, … Read more

New NPRM Makes Changes Geared to Reproductive Privacy Under HIPAA

NPRM relates to reproductive privacy under HIPAA

You’ve likely heard by now that the Office for Civil Rights (the OCR) published a Notice of Proposed Rulemaking (NPRM) on April 17, 2023, that makes changes to the HIPAA Privacy Rule to promote reproductive privacy (see the HHS Fact Sheet). The new NPRM makes changes related to uses and disclosures, and Notices of Privacy … Read more