New Guidance From OCR

As promised the Office for Civil Rights has begun releasing guidance with respect to the new provisions under the Omnibus Rule.  This week they issued a new template that incorporates changes to the Notice of Privacy Practices.  Organizations can download this from their website and use it to develop their own updated version.  Today they released guidance for three other provisions of the Omnibus Rule; guidance for prescription refills and other biologics, guidance for release of decedent information and guidance fore student immunizations.  This guidance is developed to clarify the marketing exception around receiving remuneration for refills of existing prescriptions and other biologics, for release of decedent information to those involved in the care or payment of care for a person at the end of their life and for allowing health care entities to release proof of student immunizations when required by state law and with parental or guardian consent.  Organizations need to update their Privacy policies for these important provisions and this guidance can assist identifying appropriate changes.  Further guidance around compromise, minimal necessary, etc. is expected out as well.