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Update for CoCs and HMIS Leads on Upcoming Changes to HIPAA Standards

This listserv provides an update for CoCs and HMIS Leads on the Health Insurance Portability and Accountability Act (HIPAA). HIPAA is a federal health privacy rule. It has recently been updated and HUD is in the process of determining what the impact will be on CoCs, homeless service providers, and HMIS Leads. 
HUD encourages communities to review current policies and procedures around HIPAA covered entities against the updated HIPAA rule. A HIPAA covered entity is:
  • A health care provider who bills electronically;
  • A health plan; and/or
  • A health care clearinghouse.
For more information on each of these entities, refer to the HHS CMS Covered Entity Chart.

If you have questions or concerns about HMIS privacy and security standards, please contact the HMIS TA contact for your CoC. HUD is in the process of drafting updated HMIS Privacy and Security standards, and the Notice will be published for public comment later this year. CoCs should continue to refer to the 2004 HMIS Data and Technical Standards for guidance on privacy and security.

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