HIPAA

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During the last week of August, the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) issued FAQs Part 74, addressing HIPAA nondiscrimination and wellness program rules. 

In the FAQs, the Departments confirmed that sponsors of group health plans have considerable flexibility in crafting wellness programs and should not be penalized for…

Group health plan sponsors should take note of the February 16, 2026 deadline to update HIPAA Notices of Privacy Practices (“NPPs”) to reflect recent privacy updates for Part 2 records.

What is an NPP and why does it impact employers and other plan sponsors?

HIPAA requires that covered entities, such as group health plans, provide…

Last month, a federal district court in Texas vacated portions of the HIPAA final rule that added heightened protections for reproductive health care information (the “Final Rule”). Purl, et al. v. U.S. Department of Health and Human Services, et al., No. 2:24-cv-00228-Z (N.D. Tex. June 18, 2025). As discussed in our prior blog posts…

Last week, the U.S. Departments of Labor and Treasury issued a Joint Notice requiring the extension of certain benefit plan deadlines for individuals affected by Hurricanes Helene and Milton and Tropical Storm Helene.[1] The deadline extensions echo relief issued during the COVID-19 pandemic, but apply to a more limited group of individuals. The…