Tag Archives: CMS

Have You Obtained a HPID?

The Department of Health and Human Services (“HHS”) recently released guidance on the application process to obtain a Health Plan Identifier (“HPID”).  A HPID is an all-numeric 10-digit identification number that many HIPAA-covered health plans are required to adopt by November 5, 2014.  Think of a HPID like an EIN for health plans.  HPIDs will … Continue Reading

CMS Seeks Emergency Review and Approval of its One-Hour Breach Notification Rule for Exchanges

Today, the Centers for Medicare and Medicaid Services (CMS) requested an "emergency review" of its recently proposed rule that "[Federally-facilitated Exchanges or FFEs], non-Exchange entities associated with FFEs, and State Exchanges must report all privacy and security incidents and breaches to HHS within one hour of discovering the incident or breach."  We reported on the proposed … Continue Reading

Federal Agencies Tighten Data Security Screws on Federal Contractors

Federal contractors are subject to numerous requirements under federal law and, as we have previously highlighted here, need to keep pace with changes in law and regulation.  Under the Federal Information Security Management Act of 2002 (FISMA) each federal agency is required to develop, document, and implement an agency-wide program to provide information security for … Continue Reading
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