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HIPAA Omnibus Final Rule Changes for Business Associates

See Dial-In information below in the comment section, and a link by which you can see the slides.

The U.S. Department of Health and Human Services in January announced changes to HIPAA/HITECH Act regulations that significantly affect business associates to HIPAA-Covered Entities.  As companies in the health field begin to implement changes to their compliance programs, they now must come to grips with questions such as:

  • What companies are "business associates" under the new rules?
  • Why is "business associate" status such a significant issue?
  • What changes are needed in business associate agreements?
  • What if a vendor does not agree that it is a "business associate"?  How can an upstream business associate or covered entity still do business with it?

In this program, Cooke Kobrick & Wu LLP Partner Stephen Wu will be presenting on the topic of counseling and assisting business associates in connection with the HIPAA Omnibus Final Rule.  The talk will focus on answering the above questions and helping business associates understand their obligations and comply with the new regulations.

Stephen Wu is is a partner in the Silicon Valley law firm Cooke Kobrick & Wu LLP (  He assists clients with information security and privacy compliance, policy development, breach response, litigation, insurance coverage, and establishing secure electronic commerce systems.  He served as Chair of the American Bar Association Section of Science & Technology Law last year, and before that co-chaired the Section’s Information Security Committee.  He has co-written five books on data protection and is a frequent speaker at the RSA Security Conference.  Among his books is the 2007 Guide to HIPAA Security and the Law.  His forthcoming book to be published by the American Bar Association is a legal guide to enterprise mobile device management.  He is a 1988 graduate of Harvard Law School and, before starting his private practice, he served as security giant VeriSign’s second in-house attorney.  At VeriSign, he was in charge of the company’s worldwide security and legal policies and practices governing its digital certification information security services.

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  • Mike M.

    Really excellent!

    June 26, 2013

  • Stephen W.

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    June 26, 2013

  • Kathryn C.

    Also, the BAA defines the permitted uses and disclosures of the PHI by the business associate, especially the right (or no right) of the business associate to use and/or disclose the PHI in order to aggregate data and/or de-identify the data on behalf of the covered entity. Once the data are properly de-identified under HIPAA, those data are no longer PHI. Such de-identified data may retain significant economic value. The right to de-identify PHI transmitted from the covered entity to a business associate, or downstream to a contractor from another business associate, are major rights that permit data mining by the business associate and carry value.

    1 · June 18, 2013

  • Richard W.

    Will be calling in.

    June 18, 2013

  • Christine W.

    Attending virtually

    June 18, 2013

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